1. Introduction

This Privacy Policy explains how Elson Group (Construction) Limited ("we", "us", or "our"), a company registered in England and Wales, collects, uses, stores, and protects personal data processed through our internal mobile application (the "App").

This App is strictly for use by authorised employees and subcontractors of Elson Group (Construction) Limited. It is not intended for, nor available to, the general public. By using the App, you confirm that you are an authorised user and agree to the terms of this Privacy Policy.

2. Data Controller

Elson Group (Construction) Limited Company No. 13294373 Heybridge, Essex, United Kingdom

For any privacy-related queries, please contact: info@elsongroup.co.uk

3. What Data We Collect

Depending on how the App is used, we may collect and process the following categories of personal data:

• Identity data – name, employee or contractor ID
• Contact data – work email address, work mobile number
• Location data – GPS or site location data where required for site attendance, vehicle tracking, or job allocation
• Device data – device type, operating system version, app version
• Usage data – log-in times, actions taken within the App, form submissions
• Site and project data – site attendance records, task completions, inspection reports, RAMS acknowledgements, risk assessments, and related construction documentation
• Health and safety data – accident/incident reports, toolbox talk acknowledgements, and training records (where applicable)

4. How We Use Your Data

We process your personal data for the following purposes:

PurposeLegal BasisManaging site attendance and workforce allocationLegitimate interests / Contractual necessityEnsuring compliance with CDM 2015 and health & safety legislationLegal obligationCommunicating project instructions and updatesContractual necessityMonitoring App usage for security and performanceLegitimate interestsMaintaining records required by law (e.g. accident reports)Legal obligationVerifying completed tasks, inspections, and documentationContractual necessity

We do not use your personal data for marketing purposes, profiling, or automated decision-making.

5. Data Sharing

We will only share your personal data where necessary and appropriate:

• Within Elson Group – relevant managers, site supervisors, and administrative staff on a need-to-know basis
• Clients and principal contractors – where required for CDM or contractual compliance (e.g. site registers, F10 notifications)
• Regulatory authorities – such as the Health and Safety Executive (HSE), local authorities, or other statutory bodies where legally required
• Third-party service providers – including IT support and cloud hosting providers, who are bound by data processing agreements
• Emergency services – in the event of a site incident or emergency

We do not sell your personal data to any third party.

6. Data Retention

We retain personal data only for as long as necessary:

• Employment/contractor records – retained for the duration of engagement and up to 6 years thereafter in line with statutory requirements
• Health and safety records – retained for a minimum of 3 years, or longer where required by law (e.g. RIDDOR records)
• Site and project records – retained for the duration of the project and up to 6 years thereafter
• App usage logs – retained for up to 12 months

When data is no longer required, it is securely deleted or anonymised.

7. Data Security

We take the security of your personal data seriously. Measures in place include:

• Password-protected access and user authentication
• Encrypted data transmission (HTTPS/TLS)
• Access controls limiting data visibility to authorised personnel only
• Regular security reviews of the App and its hosting infrastructure
• Secure deletion procedures

In the event of a data breach that is likely to affect your rights or freedoms, we will notify you and the Information Commissioner's Office (ICO) in accordance with our obligations under UK GDPR.

8. Your Rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights:

• Right of access – to request a copy of the personal data we hold about you
• Right to rectification – to request correction of inaccurate data
• Right to erasure – to request deletion of your data in certain circumstances
• Right to restriction – to request we limit how we use your data
• Right to object – to object to processing based on legitimate interests
• Right to data portability – to receive your data in a portable format where applicable

To exercise any of these rights, please contact us at: info@elsongroup.co.uk

We will respond to all valid requests within one calendar month.

9. Cookies and Device Permissions

The App may request access to the following device features:

• Location services – for site attendance and job allocation purposes
• Camera – for capturing site photos, document scanning, or identity verification
• Storage – for saving documents or reports locally on your device
• Notifications – for sending project updates and safety alerts

You can manage these permissions at any time through your device settings. Revoking certain permissions may limit App functionality.

10. International Data Transfers

We do not routinely transfer your personal data outside the United Kingdom. If any transfer does occur (e.g. via a cloud service provider), we will ensure appropriate safeguards are in place in accordance with UK GDPR.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Where changes are significant, we will notify users via the App or by direct communication. The date at the top of this document will always reflect the most recent version.

12. Complaints

If you believe we have not handled your personal data appropriately, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: www.ico.org.uk
• Telephone: 0303 123 1113

We would, however, appreciate the opportunity to address your concerns directly before you contact the ICO.

This Privacy Policy is governed by the laws of England and Wales.