Contents

1. Purpose ........................................................................................................ 1

2. Scope ............................................................................................................ 2

3. Your Entitlements ....................................................................................... 2

4. Your Responsibilities .................................................................................. 3

5. Procedure .................................................................................................... 4

6. Related Policies and Documents ....................................................... 6

7. Further Information ................................................................................... 6

8. Policy Owner .............................................................................................. 6

9. Policy Review Date .................................................................................. 6

1. Purpose

This policy outlines your rights and obligations in relation to your personal data and the personal data of third parties that you may come into contact with during the course of your employment.

"Personal data" refers to any information that relates to a living individual who can be identified from that information.

"Processing" refers to any use that is made of personal data, including collecting, storing, amending, disclosing, or destroying it.

"Special categories of personal data" refers to information about an individual's racial or ethnic origin, political opinions, religious or political beliefs, trade union membership, health, sex life or sexual orientation, and biometric data.

"Criminal records data" refers to information about an individual's criminal convictions and offences and information relating to criminal allegations and proceedings.

If you have access to the personal data, special categories of data, or criminal records data of employees or third parties, you must comply with this Policy. Failure to comply with this Policy and procedures may result in disciplinary action, up to and including dismissal without notice.

Data Protection Principles

Moonraker Motorcycles Ltd processes HR-related personal data in accordance with the following data protection principles:

• Moonraker Motorcycles Ltd processes personal data lawfully, fairly, and in a transparent manner.

• Moonraker Motorcycles Ltd collects personal data only for specified, explicit, and legitimate purposes.

• Moonraker Motorcycles Ltd processes personal data only where it is adequate, relevant, and limited to what is necessary for the purposes of the processing.

• Moonraker Motorcycles Ltd keeps accurate personal data and takes all reasonable steps to ensure that inaccurate personal data is rectified or deleted without delay.

• Moonraker Motorcycles Ltd retains personal data only for the period necessary for the processing.

• Moonraker Motorcycles Ltd adopts appropriate measures to ensure that personal data is secure and protected against unauthorised or unlawful processing and from accidental loss, destruction, or damage.

2. Scope

This policy applies to all employees and workers.

3. Your Entitlements

Data protection legislation prescribes the way in which Moonraker Motorcycles Ltd may collect, retain, and handle personal data. Moonraker Motorcycles Ltd will comply with the requirements of data protection legislation, and all employees and contractors who handle personal data in the course of their work must also comply with it.

Moonraker Motorcycles Ltd will inform individuals of the reasons for processing their personal data, how it uses such data, and the legal basis for processing in its privacy notices. It will not process personal data about individuals for other purposes.

Where Moonraker Motorcycles Ltd processes special categories of personal data or criminal records data to perform obligations or to exercise rights in employment law, this will be done in accordance with the rules relating to special categories of data and criminal records data.

Moonraker Motorcycles Ltd will update HR-related personal data promptly if an individual advises that their information has changed or is inaccurate.

Personal data gathered during the employment or engagement of an employee, worker, contractor, volunteer, or intern is held in the individual’s personal file (in hard copy or electronic format, or both), and on HR systems. The periods for which Moonraker Motorcycles Ltd holds HR-related personal data are detailed in its privacy notices.

Access to Your Personal Data (Subject Access Requests)

You have the right to make a subject access request. If you make such a request, Moonraker Motorcycles Ltd will inform you:

• Whether or not your data is processed, and if so, why;

• The categories of personal data concerned and the source of the data if it is not collected from you;

• To whom your data may be disclosed, including any recipients located outside the European Economic Area (EEA) and the safeguards that apply to such transfers;

• How long your personal data is stored or how that period is decided;

• Your rights to rectify or erase data, or to restrict or object to processing;

• Your right to complain to the Information Commissioner if you believe Moonraker Motorcycles Ltd has failed to comply with your data protection rights; and

• Whether or not Moonraker Motorcycles Ltd carries out any automated decision-making and the logic involved in such decision-making.

Moonraker Motorcycles Ltd will also provide you with a copy of the personal data undergoing processing. This will normally be in electronic form if you have made the request electronically, unless you request otherwise.

If you request additional copies, Moonraker Motorcycles Ltd may charge a fee, based on the administrative cost of providing those additional copies.

Other Rights

You have a number of other rights in relation to your personal data. You can require Moonraker Motorcycles Ltd to:

• Rectify inaccurate data;

• Stop processing or erase data if your interests override Moonraker Motorcycles Ltd’s legitimate grounds for processing (where Moonraker Motorcycles Ltd relies on legitimate interests as a lawful basis for processing data);

• Stop processing or erase data if it is unlawful; and

• Stop processing data for a period if it is inaccurate or if there is a dispute about whether your interests override Moonraker Motorcycles Ltd’s legitimate interests for processing the data.

4. Your Responsibilities

You are responsible for helping Moonraker Motorcycles Ltd keep your personal data accurate and up to date. You should inform Moonraker Motorcycles Ltd if personal data provided to the company changes (e.g., if you change bank accounts or move house).

You may have access to the personal data of other individuals and of our customers or clients in the course of your employment, contract, volunteer period, internship, or apprenticeship. Where this is the case, Moonraker Motorcycles Ltd relies on you to help meet its data protection obligations.

If you have access to personal data, you are required to:

• Access only data that you have authority to access and only for authorised purposes;

• Not disclose data except to individuals (whether inside or outside Moonraker Motorcycles Ltd) who have appropriate authorisation;

• Keep data secure (for example, by complying with rules on access to premises, computer access including password protection, and secure file storage and destruction);

• Not remove personal data or devices containing or that can be used to access personal data, from Moonraker Motorcycles Ltd premises without adopting appropriate security measures (such as encryption or password protection) to secure the data and the device; and

• Not store personal data on local drives or on personal devices that are used for work purposes.

Failure to observe these requirements may result in disciplinary action, which will be dealt with under Moonraker Motorcycles Ltd’s disciplinary procedure. Significant or deliberate breaches of this policy, such as accessing employee, customer, or client data without authorisation or a legitimate reason to do so, may constitute gross misconduct and could lead to dismissal without notice.

Processing Special Categories and Criminal Records Data

Moonraker Motorcycles Ltd will process special categories and criminal records data primarily where it is necessary to enable the company to meet its legal obligations, particularly to ensure adherence to health and safety legislation, vulnerable groups protection legislation, or for equal opportunities monitoring purposes.

5. Procedure

Moonraker Motorcycles Ltd keeps a record of its processing activities in respect of HR-related personal data in accordance with data protection legislation.

Personal data relating to employees may be collected by Moonraker Motorcycles Ltd for the purposes of:

• Recruitment, promotion, training, redeployment, and/or career development, such as references, CVs, and appraisal documents;

• Administration and payment of wages, such as emergency contact details and bank/building society details;

• Calculation of certain benefits, including pensions;

• Disciplinary or grievance issues;

• Performance management purposes and performance review;

• Recording communication with employees and their representatives;

• Compliance with legislation;

• Provision of references to financial institutions, to facilitate entry onto educational courses and/or assist future potential employers; and

• Staffing levels and career planning.

How We Use Special Categories and Criminal Records Data

"Special categories" and "criminal records" data require higher levels of protection. We need further justification for collecting, storing, and processing these types of personal data. We may process special categories or criminal records 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 occupational pension scheme;

• Where it is needed to assess your working capacity on health grounds;

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

Accuracy of Personal Data

Moonraker Motorcycles Ltd will review personal data regularly to ensure that it is accurate, relevant, and up to date.

To ensure accuracy and that Moonraker Motorcycles Ltd can contact you or, in an emergency, another designated person, you must notify Moonraker Motorcycles Ltd as soon as possible of any change in your personal details (e.g., name, address, telephone number, loss of driving licence, next of kin details, etc.).

Security of Personal Data

Moonraker Motorcycles Ltd will ensure that personal data is not processed unlawfully, lost, or damaged. If you have access to personal data during your employment, you must also comply with this obligation. If you believe you have lost any personal data in the course of your work, you must report it to your manager immediately. Failure to do so may result in disciplinary action, up to and including dismissal without notice.

Data Breaches

Moonraker Motorcycles Ltd will record all data breaches, regardless of their effect. If we discover that there has been a breach of HR-related personal data that poses a risk to the rights and freedoms of individuals, we will report it to the Information Commissioner within 72 hours of discovery.

If the breach is likely to result in a high risk to the rights and freedoms of individuals, we will inform affected individuals and provide them with information about the likely consequences of the breach and the mitigation measures we have taken.

Requesting Access to Personal Data (Subject Access Requests)

To make a subject access request, you should send your request to Moonraker Motorcycles Ltd. In some cases, Moonraker Motorcycles Ltd may need to ask for proof of identification before processing the request. We will inform you if we need to verify your identity and the documents we require.

We will normally respond to a request within one month from the date we receive it. In some cases, such as where Moonraker Motorcycles Ltd processes large amounts of an individual’s data, we may respond within three months of the date the request is received. We will inform the individual within one month of receiving the original request if this is the case.

If a subject access request is manifestly unfounded or excessive, Moonraker Motorcycles Ltd is not obliged to comply with it. Alternatively, we can agree to respond but will charge a fee, based on the administrative cost of responding to the request. A subject access request is likely to be considered manifestly unfounded or excessive if it repeats a request to which we have already responded. If you submit such a request, we will notify you whether or not we will respond.

6. Related Policies and Documents

• Disciplinary Policy

This list is not exhaustive.

7. Further Information

Any queries or comments about this policy should be addressed to the HR Department.

8. Policy Owner

This policy is owned and maintained by HR.

9. Policy Review Date

Date last reviewed: 01/01/2024

I made spelling corrections (e.g., "recieve" to "receive") and adjusted wording for clarity and legal precision. Additionally, I formatted the document for better readability and clarity of the content.