NKC Personal Data Policy

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NKC Personal Data Policy

NKC Manufacturing Sweden AB has adopted the following personal data policy as personal data controller for employee personal data.

This personal data policy serves to provide with information about collection, handling, storage and distribution of personal data in regard to individually identifiable employees. This includes current, previous, and future employees, regardless of type of employment, as well as hired labor. Specific management templates and guidelines may occur.

In addition to this personal data policy, national laws and regulations in states where NKC Manufacturing Sweden AB conduct business may require that the handling of personal data for employees is done in a different way than what is presented in this policy. In these cases, the subsidiaries and units act in accordance with rules applicable to their activities, in addition to this personal data policy. Mandatory laws and regulations in places where NKC Manufacturing Sweden AB conduct business are to be followed at any time, and must take precedence in case of a dispute or deviation from this personal data policy.

1. Personal data of employees that NKC Manufacturing Sweden AB handles
   NKC Manufacturing Sweden AB may handle the following personal data of the employees.
   The personal data can be collected during the process of recruitment, at the start of employment as well as during any ongoing employment at NKC Manufacturing Sweden AB.

Basic personal data: Name, data regarding birth/personal identity number, gender, business telephone number, business address, home address, other private contact details, organizational affiliation/unit, time and date of employment, time and date of termination of employment, role in management, employment rate, country of birth, blue or white collar and other basic forms of personal data where it is required.

For hiring: The employer, time of employment for staffing, time when NKC Manufacturing Sweden AB’s was terminated, as well as type of agreement.

For execution and planning of work: manager, executive of this manager, position designation, department, country, product line, region, location, education/skills, level of education, performance.

Management of staff and other HR-specific personal data: Weekly working hours, daily working hours, Trade union confederation, contact information next-of-kin, cost centre, job evaluation, group of employees, monthly salary, wage trend, pay grade, information about competence, incentive program, health information, rehabilitation, absence, manager, placement at the organizational level, results, other identification numbers, personnel department and, where necessary, other relevant data for management of staff and HR-specific personal data.

Communication: Personal data required to provide employee access to the NKC Manufacturing Sweden AB data systems and networks, which include internet address, work email, IP-addresses and username for login, order processing and support, but also other types of personal data that are stored when using data systems and networks.

2. Purpose of processing of employee personal data.
   NKC Manufacturing Sweden AB may collect and handle personal data of employees for the following purposes, amongst other things. The list is not exhaustive, but intends to give a picture of NKC Manufacturing Sweden AB’s need of processing personal data of employees.

• Administration and handling of the employment at NKC Manufacturing Sweden AB, maintenance of employment records.
• Intern management, planning and processing of workforce, need for and access to different resources, project staffing, and resource allocation.
• Recruitment, skill development, career planning and development, evaluation and monitoring of work performance
• Management of benefits, salary payments, compensation, taxes and insurance
• Management of business trips, travel insurance, secondment and other business trips
• Provide employees with access to internal information systems of the company and other resources, support secure, safe, and effective usage of internal information channels such as e-mail and other internet- or telephony-based services, ensure that business-critical information and NKC Manufacturing Sweden AB’s other assets are secure and protected
• Financial planning, reporting, establishment of budget, and analysis
• Health and work environment
• Follow up application of internal policies and other provisions, protect property of NKC Manufacturing Sweden AB, both physical and immaterial rights, prevent fraud and other illegal activities
• Handle labor-related disputes and complaints, for example compensatory claims, act in accordance with other applicable legal obligations that NKC Manufacturing Sweden AB can have through the employee’s employment at NKC Manufacturing Sweden AB

3. The legal basis of the processing
   The legal basis of the processing of personal data is fulfilling the employment contract. The legal basis is also made up of that NKC Manufacturing Sweden AB, due to law, collective agreement or other regulations is committed to process personal data in a certain way, for example relative to The National Tax Board of Sweden or insurance companies or registration of working hours etc. The legal basis may also be made up of that NKC Manufacturing Sweden AB, after balancing of interests has the right to perform the processing. In addition, NKC Manufacturing Sweden AB may process personal data with the support of the certain consent of the employee.

If the processing is required to fulfill an agreement or a legal obligation, the employee cannot oppose the process in this case.

4. How the employee personal data is protected and who has access to this
   NKC Manufacturing Sweden AB applies appropriate technical and organizational safety measures to protect personal data against events such as loss of data, abuse and unauthorized access.

Only persons within the company who in their employment need to process personal data in accordance with the above-mentioned purposes will have access to them.

NKC Manufacturing Sweden AB may distribute personal data to the Data processor, other companies within the same group or to a third party, which is described below, in accordance with appropriate data protection laws.

• To recipients within the group to enable global processing of personal data for the above-mentioned purposes.
• To the Data processor. NKC Manufacturing Sweden AB can hire Data processors for business purposes as a part of its normal business, such as for example posting management of salary for employees or IT operations on external supplier. In these cases, NKC Manufacturing Sweden AB will require such Data processors to use appropriate technical and organizational safety measures to protect the personal data of employees, and so that the processing of personal data for the employees is only done in accordance with the instructions of NKC Manufacturing Sweden AB.
• To authorities if NKC Manufacturing Sweden AB has an obligation to do so, or if NKC Manufacturing Sweden AB has to protect their rights or any third-party rights.
• To third parties in conjunction with sales or any other transfer as part of NKC Manufacturing Sweden AB’s business.
• To third parties in conjunction with emergency, where health and safety for employees or any other person is in dangerTill tredje part i samband med nödfall där hälsa och säkerhet för anställd eller annan person är i fara.
• To third parties in order to defend the rights of NKC Manufacturing Sweden AB, for example in connection with labor disputes.
• To authorities and/or employer organization for pay data.

Some recipients of personal data of the employees can be located or have activities in another country than the one where the employee’s establishment is located. The privacy legislation can look different in these countries. NKC Manufacturing Sweden AB’s will assure that an adequate level of protection is maintained for the processing of personal data in each transfer of personal data.

5. Storage- and thinning times for personal data
   NKC Manufacturing Sweden AB will process and store personal data of employees for as long as necessary in relation to the purposes that the data is collected for.

Some personal data will be deleted in connection to termination of employment. Other personal data will be stored during a longer time, since there is a legal obligation for NKC Manufacturing Sweden AB to retain the personal data, for example in order to maintain an employer’s certificate or to strengthen that tax deduction is done in a correct way, alternatively, that NKC Manufacturing Sweden AB needs this data to defend/make use of their rights. As soon as the opportunity to direct claims against NKC Manufacturing Sweden AB expires (limitation), the data will be deleted. NKC Manufacturing Sweden AB may also need to save personal data that is associated with specific projects and these may therefore need to be saved as long as the projects are in progress.

Some personal data may be saved during a longer time, such as information regarding employment period, until the employee reaches retirement age according to the Employment Protection Act.

6. Employee rights
   The employee has the right to access their personal data, demand correction of personal data, oppose processing of personal data, demand that processing of personal data is limited, or demand deletion of their personal data that is processed by NKC Manufacturing Sweden AB, according to the rights following the Data protection legislation. These rights can be limited by other regulations in the Data protection legislation, or if a demand would be considered improper in a specific case, for example depending on an ongoing investigation regarding improper conduct.

The employee has the rights to revoke consent provided for certain processing of personal data.

The employee can have the rights to transfer his/her personal data to another Data controller. This regards personal data that NKC Manufacturing Sweden AB process with support from consent provided by the employee, or to fulfill an agreement with the employee. The data shall be provided to NKC Manufacturing Sweden AB in a structured, commonly used and machine-readable format.

If an employee has questions or wants to claim any of these rights, the IT manager or HR should be contacted.

Employees can receive more information about the handling of personal data through HR, the IT manager or immediate supervisor.

Employees have the right to the data inspectorate with complaints regarding the processing of their personal data.

7. Changes in the privacy policy
   NKC Manufacturing Sweden AB may make changes to this privacy policy. At the top of the first page, you will see when the last changes were made. If more interventional changes occur, the employees will be informed in particular.
8. Contact information
   NKC Manufacturing Sweden AB, with address Kvibergs Broväg 10, are Data controllers of the processing of your personal data. This means that NKC Manufacturing Sweden AB are responsible for that the processing of your data is done correctly and in accordance with the applicable data protection legislation.

HR and IT-functions represent NKC Manufacturing Sweden AB in matters regarding processing of personal data and can be reached by the following contact information.