EMPLOYEE PERSONAL INFORMATION PRIVACY NOTICE

JC & RH Palmer Limited (Palmers Brewery) care about your privacy and are committed to processing your personal information in accordance with fair information practices and applicable data privacy laws.

Scope

This notice explains how Palmers Brewery handles the personal information of employees, applicants, interns, former employees, dependents, beneficiaries, contractors, consultants and temporary agency workers in the course of its human resources activities. We may amend this notice from time to time, should it become necessary to do so.

Collection and Use of Personal Information

We may process your personal information for legitimate business purposes to administer our employment or contractual relationship with you and to run our businesses. We may collect, use and transfer your personal information through automated and/or paper-based data processing systems. We have established routine processing functions (such as processing for regular payroll and benefits administration). We also process personal information on an occasional or ad hoc basis (such as when an employee is being considered for a particular new position or in the context of changes to its marital status for example).

In the normal course of human resources activities, we can collect the following types of personal information:

Personal identification information, such as your name, home address, date of birth, gender, work­ related photographs, and home phone number;
Government-issued identification numbers, such as national ID for payroll purposes; Immigration, right-to-work and residence status;
Family and emergency contact details;
Job-related information, such as years of service, work location, employment ID, work record, vacation absences, and contract data;
Educational and training information, such as your educational awards, certificates and licenses, vocational records and in-house training attendance;
Recruitment and performance-related data, such as objectives, ratings, comments, feedback results, career history, work equipment, career and succession planning, skills and competencies and other work-related qualifications;
Information related to your usage of Palmers Brewery assets;
Information needed for compliance and risk management, such as disciplinary records, background check reports and security data; and
Payroll- and payment or benefits-related information, such as salary and insurance information, dependents, government identifier or tax numbers, bank account details, and employment related benefits information.

We process personal information for the following purposes: (1) workforce planning, recruitment and staffing; (2) workforce administration, payroll , compensation and benefit programs; (3) performance management , learning and development ; (4) advancement and succession planning; (5) legal compliance, including compliance with government authority requests for information, liens, garnishments and tax compliance; (6) workplace management , such as travel and expense programs and internal health and safety programs , (7) internal reporting , (8) audit; (9) to protect Palmers Brewery, its work force, and the public against injury, theft, legal liability, fraud or abuse; and (10) other legal and customary business-related purposes.

In addition, we may process sensitive personal information if it is needed for legitimate business objectives or if it is required to comply with applicable law. Sensitive personal information will not be collected, processed or transferred, except where adequate privacy protection mechanisms are in place and after having first obtained your informed consent, if required by law.

Disclosures

We may disclose your personal information for legitimate purposes in the following circumstances to:
• Other Palmers Brewery entities, joint ventures, subcontractors, vendors or suppliers who perform services on our behalf for the aforementioned purposes;
• A newly formed or acquiring organization if Palmers Brewery is involved in a merger, sale or a transfer of some or all of its business;
• Any recipient, if we are required to do so, such as by applicable court order or law;
• Any recipient, with your consent, such as for employment verification or bank loans; or
• Any recipient when reasonably necessary such as in the event of a life-threatening emergency.

Choice

We respect your right to object to any uses or disclosures of your personal information that are not (i) required by law, (ii) necessary for the fulfillment of a contractual obligation (e.g., employment contract), or
(iii) required to meet a legitimate need of Palmers Brewery as an employer (such as disclosures for internal auditing and reporting purposes or other processing covered by this notice). If you do object, we will work with you to find a reasonable accommodation.

Transfers

Your personal information may be transferred outside of the country where you work. Palmers Brewery is committed to protecting the privacy and confidentiality of personal information when it is transferred. Where such transfers occur, we will assure that adequate protection exists either through appropriate contractual arrangements or as required by law.

Accuracy

We take reasonable steps to ensure that personal information is accurate, complete, and current. Please note that you have shared responsibility with regard to the accuracy of your personal information. Please notify the Company Secretary or payroll of any changes to your personal information or that of your beneficiaries or dependents.

Access

You may reasonably access and update the personal information pertaining to you that is on file with Palmers Brewery. You can exercise this right by contacting the Company Secretary. Please note that:

• Your ability to access and correct personal information is not limited by transfers of personal information – the ability shall exist regardless of where personal information is physically situated within Palmers Brewery.

• Your right to access your personal information may have some restrictions. For example, access may be denied (i) in the case of recurrent access requests within a short time interval, or (ii) where providing such access or correction could compromise the privacy of another person or unreasonably expose sensitive company information.