ANGLO-EASTERN PRIVACY

NOTICE

for Seafarers

What is the purpose of this Privacy Notice?

This Privacy Notice sets out the basis on which the Company, Anglo-Eastern, will process your
personal data and your special categories of personal data in accordance with the Data
Protection Legislation.

Key Terms

When we refer to Data Protection Legislation, we mean the General Data Protection
Regulation (Regulation (EU) 2016/679) (“GDPR”); any legislation implemented by a national
authority to give effect to the derogations permitted under the GDPR.

Personal data is information that can be used to identify or contact a specific individual, such
as a name, address, telephone number, email address, etc., and online identifiers and location
data such as IP addresses and mobile device IDs.

Special category data means personal information revealing your racial or ethnic origin;
political opinions; religious or philosophical beliefs; or trade union membership; genetic data;
biometric data; data related to your health or data concerning your sex life or sexual orientation;
and criminal convictions or involvement in criminal proceedings.

A data controller is someone who decides why personal data is to be collected and how it will
be used and treated.

Contract refers to the employment contract.

The Company and Contact

Where, the Company handles your personal data and / or special categories of personal data,
it is the data controller for the purposes of the Data Protection Legislation.

If you have any questions regarding the Privacy Notice you can contact the Company’s Data
Protection Officer at dpo@angloeastern.com.

If you are unhappy with how we handle your personal information you can:

• submit a complaint to the Company’s Data Protection Officer at

dpo@angloeastern.com; and / or

• notify your national data protection authority.

Our group Data Protection Officer is Sheryl Landman and you can contact her at:

• E-mail: dpo@angloeastern.com

• Telephone: +44 (0)141 353 1020

• Mobile: +44 (0)7771 354 469

What personal data will we process?

Usually the Company will have access to the following personal data: your employee number;
your full name including, if applicable, your preferred name and your previous surname; your
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gender; your work and personal e-mail address; your marital status; your date of birth; your job
title; your bank account details; your home address; your mobile number and your home phone
number; your dates of employment and previous employment history;

your professional membership details and training certificates (if applicable); your passport
details and birth certificate; reference details; and next of kin details.

How will we use your personal data?

The Company will hold and process your personal data and special categories of personal data
to carry out its human resources, payroll and other similar functions; namely:

• maintaining your employment records;

• administering and managing its employment relationship with you;

• monitoring performance and attendance;

• carrying out appraisals;

• generating reports, records and statistics;

• engaging in disciplinary and grievance proceedings;

• administering rewards and benefits;

• managing your learning and development;

• managing holidays and leave;

• facilitating management decisions;

• detecting fraud;

• maintaining a staff directory;

• administering workplace schemes and initiatives;

• managing absences and sick pay;

• managing any disabilities or special needs you have including administering

adjustments to work;

• assessing fitness to work;

• dealing with legal disputes involving you, or other employees, workers and contractors,
including accidents at work and employment disputes;

• complying with health and safety obligations;

• to monitor your use of our information and communication systems to ensure

compliance with our IT policies;

• to ensure network and information security, including preventing unauthorized access

to our computer and electronic communications systems and preventing malicious
software distribution;

• to conduct data analytics studies to review and better understand employee retention
and attrition rates;
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 • equal opportunities monitoring;

Legal basis on which the Company uses your personal data

The Company will use your personal data on the following legal basis:

• it is necessary for the performance of this Contract; and therefore if you do not wish to
provide the personal information requested, this Contract and your employment may
not be able to continue;

• it is necessary for the Company to comply with its legal obligations;

• the processing is necessary for the purposes of the legitimate interests pursued by the
Company or those of someone else except where your interest and rights override
those interests. The Company’s legitimate interests include the operation of its business
and in doing so, the booking
/ facilitation of business travel arrangements for staff carrying out work for the Company,
and/or

• it is necessary to protect your interests or those of someone else.

Legal basis on which the Company uses your special categories of personal data

The Company will use your special categories of personal data on the following legal basis:

• it is necessary for the purposes of carrying out the obligations and rights of the
Company in the area of employment; and it is authorized by EU law;

• it is in the public interest, for example it is necessary to assess equality of opportunity

or treatment, or to prevent fraud;

• it is necessary to protect your vital interests or those of someone else and you are not
able to give consent;

• it is necessary to establish, exercise or defend legal claims;

• the use relates to personal data which is manifestly made public by you; and/or

• in certain cases, where we have your express written consent.

Legal basis on which the Company uses information about criminal convictions and
offences

The Company will only collect information about criminal convictions if it is appropriate given
the nature of the role. The Company may also only use information relating to criminal
convictions where the law allows it to do so. Where appropriate, the Company will collect
information about criminal convictions as part of the recruitment process or the Company may
be notified of such information directly by you in the course of you working for the Company.
The Company will use information about your criminal convictions and offences on the
following legal basis:
• it is necessary to carry out the Company’s obligations and provided the Company does

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 so in line with this policy;

• it is necessary to establish, exercise or defend legal claims;

• it is necessary to protect your interests (or someone else's interests) and you are not
capable of giving your consent; and/or

• you have already made the information public.

How do we keep your personal information up-to-date?

Please contact your local HR or administration team as soon as possible if there is any change
to your personal details, including your contact details.

How long the Company will hold onto your data?

The Company will not store your personal data and / or special categories of personal data
longer than necessary for the uses outlined above, unless it is required to do so to comply with
the law and / or any regulatory requirements.

The Company shall retain your information in accordance with the relevant national legislation.

Sharing your data with third parties

The Company contracts with third party service providers and suppliers to deliver certain
services, such as outsourced payroll and business travel.

The Company may share your personal information or special categories of personal
information with the following third parties:

• any other person who is authorized to act on your behalf, including approved
recruitment agencies.

• regulators, government departments, law enforcement authorities, tax authorities and

insurance companies.

• any relevant dispute resolution body or the courts.

• outsourced payroll/benefits/pension providers, if appropriate.

The Company may also need to share your personal data from time to time to comply with the
national legislation requirements.

European Economic Area

The Company may transfer data outside the EEA where our service providers host, process,
or store data outside the EEA. Where we do this, we will ensure that the transfer is to a country
covered by a decision of the Commission of the European Union or is otherwise made in
circumstances where we have put appropriate safeguards in place to protect your data in
accordance with the Data Protection Law:

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Your Rights

You have certain rights under the Data Protection Legislation which can be exercised by
contacting the Company’s Data Protection Officer at dpo@angloeastern.com, including:

• the right to access the personal data held about you by making a subject access
request in accordance with the Data Protection Legislation. We may charge a
reasonable fee when a request is manifestly unfounded or excessive;

• the right to have your personal data rectified if it is inaccurate or incomplete;

• the right to have your personal data deleted in certain specific circumstances as set
out in the Data Protection Legislation;

• the right to request to restrict the processing of your personal data in certain specific
circumstances as set out in the Data Protection Legislation;

• the right to request the transfer of your personal data to another party in certain specific
circumstances as set out in the Data Protection Legislation; and

• the right to ask us to not allow your data to undergo automated decision making; and

• where you have provided consent, to withdraw such consent at any time.

There are some exceptions to the above rights that are permitted under the Data Protection
Legislation.

Please send any objections, complaints, concerns, requests for further information, requests
for copies of your personal data, and/or application of the Rights of the Individual via email to
dpo@angloeastern.com.

If you are not satisfied with our response or believe we are processing your personal data in
a manner not in accordance with relevant legislation, you have the right to lodge a complaint
with the supervisory authority in the place of your habitual residence, place of work or the
place where you believe the infringement has occurred.

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