GNT Privacy Statement - Employee data

Version 09-05-2018 This privacy statement relates to the processing of your personal data as an employee or ex-employee of GNT International B.V. or GNT Group B.V. (hereafter referred to as ‘GNT’, ‘our’ or ‘we’). This personal data will be processed according to the General Data Protection Regulation (‘GDPR’) and local legislation and regulations (together referred to as ‘the privacy legislation’). It may of course be the case that you are concerned about the amount of data from you that we process. For that reason, we are clearly explaining in this statement what we do. However, if you still have questions about this, you are always welcome to ask. This statement is meant to inform you about the way in which we process your personal data and which rights you have in this respect. The following topics are explained below:

• What is personal data?
• For what purposes does GNT process your personal data?
• With whom does GNT share your personal data?
• How long does GNT store your personal data?
• How is your personal data safeguarded?
• How can changes to this privacy statement be made?
• What are your rights?
• Who can I contact about this?

1. Personal data and purposes

What is personal data?

Within the privacy legislation, mention is made of personal data. This could for instance be a name or telephone number, but also a date of birth, email address or membership of a trade union. When we refer to employee data, we mean the personal data of GNT employees. For what purposes does GNT process your personal data? We process your personal data only if this is allowed according to the privacy legislation. Below you can read which personal data GNT collects and for which purpose. This may involve more than your own data. Sometimes it is necessary to collect and process your partner’s data, or data of your family members, such as your children. In this case, the same rules apply: GNT will only collect and process their data if there is a good reason for doing so, for example:

A) In order to implement an employment agreement

We process the following personal data related to the employment agreement, including details concerning contact with the employer, assessments of the employee’s performance, salary payments, pension payments and other payments due to the employee:

• Name, address, telephone number, email address, gender, date of birth, marital status ordetails of registered partnership or other form of cohabitation;
• Citizen’s Service Number (‘BSN’ in Dutch), copy of passport or identity document, passport photo, handicap (if applicable);
• CV, education, diplomas, witness statements, data concerning your performance;
• Periods of leave, time recordings, staff benefits;
• Details about the use of your lease car, such as fuel use (see car regulations); and
• Bank details, pension details and insurance details.

The above data is necessary in order to enter into the employment agreement with you. After all, we need to know who is working for GNT and how we should pay salaries. If you do not provide us with these details, no employment agreement can be drawn up or the possibility may arise that you may for example not receive sums of money that you are entitled to.

B) Legal requirements

Besides this, we process the personal details below in order to fulfill the legal requirements to which GNT is subject, for example due to the Sickness Benefits Act (Ziektewet), Pension Act (Pensioenwet) and tax and Customs legislation:

• Name, address, telephone number, gender, date of birth, marital status, handicap (if applicable);
• Citizen’s Service Number (BSN), copy of passport/identity document;
• In certain cases, a Certificate of Good Conduct (‘VOG’ in Dutch); and
• Staff benefits, bank details, pension and insurance details.

The above data is necessary in order for us to fulfill our legal obligations. If you do not provide us with these personal details, GNT cannot fulfill its legal obligations.

C) Legitimate interest

In addition to the above, GNT makes use, on a limited scale, of security cameras at the entrances and exits of the buildings. GNT has a legitimate interest in deploying these security cameras in order to be able to guarantee the safety of its employees and of its products in the production and testing areas, and in order to protect its property. There is no question of using this camera supervision to track employees.

2. With whom does GNT share your personal data?

GNT may possibly provide the above-mentioned personal data to:

• The Health & Safety Service (Arbodienst) if GNT is obliged to do so on the basis of the Sickness Benefits Act (Ziektewet) and the Eligibility for Permanent Invalidity Benefit [Restrictions] Act (Wet Verbetering Poortwachter);
• Governmental institutions such as the Employment Insurance Administration Agency (UWV) and the Dutch Tax Office (Belastingdienst), including the Customs authority (Douane) to the extent that this is necessary in order to comply with legal obligations; and
• The police, judiciary and bailiffs, to the extent that GNT is legally obliged to cooperate with the requests and claims of these parties.

GNT may in addition also make use of other parties in respect of carrying out the collection and processing of employee data, such as the company that processes the salaries, or the company that arranges collective insurance policies for us. These other parties are ‘processors’ for GNT, and process your data solely on behalf of us, and not for any other purpose. In this instance, GNT remains responsible for the processing. Finally, GNT may also supply your personal data to other companies within the GNT Group. These may be located within the European Economic Area or outside it. This will only ever happen if it is necessary in order to maintain contacts within the GNT Group. GNT has concluded an agreement with its group companies in which suitable safeguards have been taken in order to protect privacy. In order to view this agreement, you may get in contact with us by using the contact details below.

3. Storage period

The law states that personal data may not be stored for any longer than necessary. Our position on this matter is as stated below:

How long does GNT store your personal data for?

• Data in your personnel file concerning your CV, education, diplomas, witness statements and performance will be destroyed two years after the end of your employment;
• The other details in your personnel file will be stored for 5 years, based on the storage requirements set out by law;
• The copy of your passport will be stored for 5 years, based on the storage requirements set out by law;
• For specific financial data, the fiscal storage requirement will be adhered to for 7 years, based on the General State Taxes Act (Algemene Wet inzake rijksbelastingen).

4. Safeguarding of your personal data

We have taken the necessary technical and organizational measures to safeguard your personal data against loss or another form of unlawful processing. GNT shall report a possible data leak in a timely manner and, if necessary, inform you of this.

Changes to this privacy statement

We may change this privacy statement from time to time if there is a reason to do so. If this happens, we shall communicate this information in the usual manner. You can always find the latest version of this privacy statement on GiNA, next to the older versions.

What are my rights?

It’s important for us to be able to keep your personal data up to date in order to avoid communication errors. You can therefore get your personal data updated, corrected or removed at any time. In addition, according to the law, you have the right to ask us to:

• let you view your personal data;
• lodge an objection against the processing of your personal data;
• limit the processing and transfer of your personal data; and/or
• transfer your personal data to yourself or to a third party.

We shall assess your request in accordance with the privacy legislation. GNT will then, as soon as possible, but in any case within a month after receiving your request, provide you with information about the activities that we have undertaken with regard to your request. In special circumstances, we may extend this deadline by two months, for example in connection with the complexity of your request or with the number of requests that GNT receives. In that case, GNT will keep you informed. In addition, you have the right at any moment to submit a complaint to the Supervisory Authority (Autoriteit Persoonsgegevens).

5. Contact

If you have any questions about this privacy statement, please contact:

Annet van Leenders

• Head of Group HR
• avleenders@gnt-group.com
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GNT Group B.V.

• Industrieweg 26
• 5731 HR Mierlo
• Netherlands
• Phone: +31 40 7800 300
• Fax: +31 40 7800 309