What is the purpose of this document?

Flexy Commercial Group Limited (Company No. 12956546), having its registered office at Staveley Main Street, Grendon Underwood, Aylesbury, England, HP18 0SL, is committed to protecting the privacy and security of personal information of both our employees and clients/customers in accordance with the UK Data Protection Act 2018, UK GDPR, and other applicable privacy laws and regulations. This privacy policy describes how we collect and use personal information about you whether as an employee during and after your working relationship with us, or as a client/customer during and after your business relationship with us, in accordance with the UK General Data Protection Regulation (UK GDPR).

Flexy Commercial Group Limited (Company No. 12956546) is a “data controller” under applicable data protection laws. This means that we are responsible for deciding how we hold and use personal information about you, whether as an employee or client. We are required under data protection legislation to notify you of the information contained in this privacy policy and to maintain appropriate technical and organisational measures to protect your data.

This policy applies to current and former employees, workers, contractors, clients and customers of the Company. We may update this policy at any time. If we do so, we will provide you with an updated copy of this policy as soon as reasonably practical and in any event within one month of any substantial updates.

It is important that you read and retain this policy, 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 that information and what your rights are under the data protection legislation.

Data protection principles

We will comply with data protection law, which 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 kind of information we hold about you

Personal data, or personal information, means any information about an individual from which that person can be identified, whether they are an employee, client, or customer. This includes information collected through our website, cleaning services, mastic services, air tightness testing services, and related business operations. This may include property information, service schedules, and testing results. It does not include data where the person’s identity has been removed (anonymous data). There are certain types of more sensitive personal data (known as special categories of personal data under UK GDPR) which require a higher level of protection, such as information about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sexual orientation, genetic data, biometric data, or data concerning criminal convictions and offences.

We will collect, store and use different categories of personal information depending on whether you are an employee or a client. For employees, these categories include:

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

· Date of birth

· Gender

· Marital status and dependants

· Next of kin and emergency contact information

· National Insurance number

· Bank account details, payroll records and tax status information

· Salary, annual leave, pension and benefits information

· Start date and, if different, the date of your continuous employment

· Leaving date and your reason for leaving

· Location of employment or workplace

· 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)

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

· Compensation history

· Performance information

· Disciplinary and grievance information

· CCTV footage and other information obtained through electronic means such as swipe card records

· Information about your use of our information and communications systems

· Photographs

· Results of HMRC employment status check, details of your interest in and connection with the intermediary through which your services are supplied.

We may also collect, store and use the following more sensitive types of personal information:

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

· Trade union membership

· Information about your health, including any medical condition and sickness records, including:

· where you leave employment and under any share plan operated by a group company the reason for leaving is determined to be ill health, injury or disability, the records relating to that decision;

· details of any absences (other than holidays) from work including time on statutory parental leave and sick leave;

· any health information in relation to a claim made under the permanent health insurance scheme; and

· where you leave employment and the reason for leaving is related to your health, information about that condition needed for pensions and permanent health insurance purposes.

· Genetic information and biometric data

· Information about criminal convictions and offences

How is your personal information collected?

We collect personal information in different ways depending on your relationship with us. For employees, workers and contractors, we collect information through the application and recruitment process, either directly from candidates or from employment agencies and background check providers. For clients using our cleaning, mastic, and air tightness testing services, we collect information when you book our services, during property assessments, through service agreements, when scheduling appointments, during service delivery, and through follow-up communications. This includes property details, access instructions, service requirements, and testing results where applicable. We may sometimes collect additional information from third parties including credit reference agencies, identity verification services, or other authorised sources in compliance with applicable laws.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

How we will use information about you

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:

1. Where we need to perform the contract, we have entered into with you. 2. Where we need to comply with a legal obligation. 3. Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests. We may also use your personal information in the following exceptional circumstances, which apply to both employees and clients: 1. Where we need to protect your interests (or someone else’s interests). 2. Where it is needed in the public interest or for official purposes.

Situations in which we will use your personal information

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, provided your interests and fundamental rights do not override those interests.

We maintain detailed records of our processing activities and regularly review these to ensure we have a valid legal basis for each type of processing, whether for employee or client data. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

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 for employees, or delivering our cleaning, mastic, and air tightness testing services for clients), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers, providing necessary testing certifications, or to verify client identity as required by law).

Change of purpose

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.

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. However, we will always inform you about such processing as soon as it is legally permissible to do so and will maintain detailed records of any such processing activities.

How we use particularly sensitive personal information

Special categories of particularly sensitive personal information, such as information about your health, racial or ethnic origin, sexual orientation, or trade union membership, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document

and safeguards which we are required by law to maintain when processing such data. We may process special categories of personal information in the following circumstances: 1. In limited circumstances, with your explicit written consent. 2. Where we need to carry out our legal obligations or exercise rights in connection with employment. 3. Where it is needed in the public interest, such as for equal opportunities monitoring or in relation to our occupational pension scheme. 4. Where it is necessary to protect you or another person from harm, such as in emergency situations or when required for the provision of critical services. Less commonly, we may process this type of information 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.

Situations in which we will use your sensitive personal information

In general, we will not process particularly sensitive personal information about you unless it is necessary for performing or exercising obligations or rights in connection with employment or the provision of our services, including meeting specific needs of our clients or ensuring appropriate service delivery. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so.

Do we need your consent?

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, whether in the context of employment law for our employees or to fulfil regulatory requirements related to our client services. 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. Where we request consent, you have the right to withdraw it at any time by contacting position/department.

We do not need your consent where the purpose of the processing is to protect you or another person from harm or to protect your well-being and if we reasonably believe that you need care and support, are at risk of harm and are unable to protect yourself.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. For employees, this relates to employment obligations. For clients, this is limited to specific regulatory requirements such as financial crime prevention and anti-money laundering compliance. All such processing is conducted in accordance with our Data Protection Policy and applicable laws, with strict access controls and security measures in place.

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. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences in the following ways:

Automated decision-making

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: 1. Where we have notified you of the decision and given you one month to request a reconsideration. 2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights. 3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights. If we make an automated decision on the basis of any particularly sensitive personal information, whether for employment or client service purposes, we must have either your explicit written consent or it must be justified in the public interest. We will implement robust safeguards including regular algorithmic bias testing, human oversight procedures, and clear appeal mechanisms to protect your rights.

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. This applies to both employment-related decisions and decisions affecting our client services, such as credit assessments, service eligibility, or pricing determinations.

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.

Data sharing

We may share your personal data with third parties, including third-party service providers (such as testing certification bodies, quality control assessors, and specialised cleaning equipment suppliers) and other entities in our group, only when necessary for legitimate business purposes, to fulfil our contractual obligations related to cleaning, mastic, and air tightness testing services, or when legally required. Any such sharing will be conducted in accordance with applicable data protection laws and our data sharing policies. 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 UK. If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with third parties only where required by law, where it is necessary to administer our relationship with you (whether as an employee or client), or where we have another legitimate interest in doing so. For clients using our cleaning, mastic, and air tightness testing services, this may include sharing relevant information with certification bodies for air tightness testing, quality assurance partners, and scheduling systems to deliver our services effectively. We will always inform you about such sharing unless prohibited by law, and will ensure appropriate data processing agreements incorporating strong security and confidentiality provisions are in place with all third parties. We maintain a regularly updated register of all third parties with whom we share data and conduct regular compliance audits are in place with all third parties.

Which third-party service providers process my personal information?

Third parties include third-party service providers (including contractors and designated agents) and other entities within our group. We engage third-party service providers for: (1) Internal operations: payroll, pension administration, benefits provision and administration, and IT services; (2) Client services: payment processing, cloud hosting, customer support systems, and analytics; and (3) Security services: fraud prevention, identity verification, and cybersecurity protection.

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

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.

What about other third parties?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your personal information with regulators or other authorities to comply with our legal obligations. This includes making returns to HMRC, disclosures to the Information Commissioner’s Office, financial regulators for client protection purposes, and where applicable, disclosures to stock exchange regulators and shareholders in accordance with company law requirements. We will always notify affected individuals of such disclosures unless prohibited by law or regulatory requirements.

Transferring information outside the UK

We may transfer the personal information we collect about you to countries outside the UK where our group companies or third-party service providers operate. Such transfers will only occur when necessary for our business operations and when appropriate safeguards are in place, including Standard Contractual Clauses, adequacy decisions, or other approved transfer

mechanisms in accordance with UK data protection laws. Where such transfers occur, we ensure appropriate safeguards are in place in accordance with UK data protection laws.

To ensure your personal information receives an adequate level of protection during international transfers, we have implemented comprehensive safeguards including: (1) Standard Contractual Clauses approved by the UK Information Commissioner’s Office, (2) Binding Corporate Rules for intra-group transfers, and (3) regular third-party security audits. Detailed information about these protective measures is available on our secure client portal, through your account manager for clients, or via the HR Department for employees. Our Data Protection Officer is available to address any specific concerns about international data transfers.

Data security

We have implemented robust technical and organisational measures to protect the security of your information, including encryption, access controls, and regular security assessments. Details of these measures are available from our Data Protection Officer and in our Information Security Policy, which can be accessed through our secure portal by both employees and clients with appropriate authentication. Third parties, including any subcontractors for cleaning, mastic services, or air tightness testing, will only process your personal information on our instructions and where they have signed comprehensive data processing agreements that include: (1) strict confidentiality obligations, (2) specific security requirements including encryption and access controls, (3) regular security audits and compliance monitoring, (4) breach notification requirements, and (5) data deletion protocols. We maintain the right to audit these security measures and require immediate remediation of any identified issues.

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, including specific protections for service location access codes, testing results, and client property information. Additionally, 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.

We have implemented a comprehensive incident response plan to address any suspected data security breaches. This includes: (1) immediate containment measures, (2) prompt investigation procedures, (3) a 72-hour notification timeline to relevant supervisory authorities where legally required, (4) direct communication with affected individuals through secure channels, and (5) post-incident review and security enhancement processes. We maintain dedicated emergency contact channels for both employees and clients to report suspected security incidents.

Data retention

How long will you use my information for?

We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. Our retention periods vary based on the type of relationship (employee or client) and the nature of the data. For employees, this typically includes employment records, payroll, and benefits information. For clients receiving our cleaning services, mastic services, or air tightness testing services, this includes contact information, service locations, service history, inspection reports, testing results, and payment records. Our detailed Data Retention Policy is available on our secure portal for employees and can be requested by clients through our Data Protection Officer.

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 whether we can achieve those purposes through other means.

· The applicable legal requirements.

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 that information without further notice to you. For employees, once your employment or contractual relationship with us ends, we will retain and securely destroy your personal information in accordance with our Data Retention Policy. For clients, we will retain your information for the duration of our business relationship and any applicable statutory periods, after which it will be securely destroyed or anonymised in accordance with our Data Retention Policy and applicable laws.

Rights of access, correction, erasure and restriction

Your duty to inform us of changes

It is important that the personal information we hold about you is accurate and current. For employees, please notify HR of any changes during your employment. For clients using our cleaning services, mastic services, or air tightness testing services, you can update your information through your account settings on our secure client portal, by contacting your service coordinator, or by notifying our team during service visits. This includes changes to property access information, contact details, or service location specifics. Keeping your information up-to-date helps us maintain service quality and ensure effective communication. Please keep us informed if your personal information changes during your working relationship with us.

Your rights in connection with personal information

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

· 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.

· 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.

· 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).

· 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.

· 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.

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

If you want to exercise any of your data protection rights, including accessing, correcting, erasing, or transferring your personal information, or objecting to its processing, please contact our Data Protection Officer in writing at [email address] or [postal address]. For requests related to cleaning services, mastic services, or air tightness testing records, please include your client reference number and service location details to help us process your request efficiently. We will respond to your request within one calendar month.

No fee usually required

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 these circumstances.

What we may need from you

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 verification process may differ depending on whether you are an employee or client, but will always include appropriate security measures to protect your personal information. For online access requests, we use multi-factor authentication and secure communication channels to ensure personal information is not disclosed to unauthorised persons.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information 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 the DPO. For service-specific consent withdrawals (such as marketing communications about our cleaning, mastic, or testing services), you can also manage your preferences through our secure client portal or by contacting your service coordinator. 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 reason for doing so by law.

Data protection officer (DPO)

We have appointed a Data Protection Officer 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 our DPO at info@flexycleaning.com. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

Changes to this privacy policy

We reserve the right to update this privacy policy at any time. We will provide you with an updated privacy policy at least 30 days before implementing any substantial changes, unless immediate changes are required by law. For substantial updates, we will notify you through email (for employees) or through our website and email (for clients), and may use additional communication channels as appropriate. All updates will be clearly dated and versioned, with previous versions remaining accessible upon request. Any changes affecting the processing of your personal information will be clearly highlighted in the updated policy. We may also notify you in other ways from time to time about the processing of your personal information.