Personal Data Processing Information
This Personal Data Processing Information notice (“Information”) is for the information of any person entering or applying to enter the construction site (“Construction Site”) of Exyte Northern Europe Ltd in Denmark (Denmark 01).
With this Information we would like to inform you about how we process your personal data (“Personal Data”), what rights you have as data subject, and provide you with other helpful material about data processing.
The Information is limited to how we process your Personal Data at the Construction Site.
There may be other circumstances in which you come in contact with us and where we process your Personal Data differently, e.g. as employee, as personnel of a sub-contractor or as visitor to our website.
We usually provide you with data protection information in those circumstances separately to keep you informed.
However, if you want to read-up on other data processing information, you can find the information for the following circumstances under the following links:
- As employee of Exyte Northern Europe Ltd. on OneNet under the following link in one net (you need to be on a work computer);
- As business partner, personnel of a client,supplier, sub-contractor or other party under the following link, whereas Exyte Central Europe GmbH is the controller.
- Data processing on our website under the following link.
Please note that if you are working for a client or sub-contractor, supplier etc. (“Business Partner”), the Business Partner may process your Personal Data independent from us, even while you are on the Construction Site.
Furthermore, our client may have additional security measures in certain areas, which are under the sole control of the client and where the client is controller of your Personal Data. Please refer to the Business Partner or the client for further information, including your rights with regard to such Personal Data.
If we refer to “you” as reader of the Information, we assume that you are the “Data Subject” whose Personal Data we process.
1. Name and contact details of the controller as defined under the General Data Protection Regulation: (GDPR)
Exyte Northern Europe Ltd
Unit J3, Maynooth Business Campus, Maynooth
Co. Kildare, W23 AZW4, Ireland www.exyte.net
(following: “we”, “us” or “Exyte”)
2. Data Protection Officer
The Exyte Group has appointed a Data Protection Officer (“DPO”). You can reach the DPO at the following email address: privacy@exyte.net.
Please feel free to contact the DPO in case of any questions, complaints, enquiries or suggestions regarding processing Personal Data at Exyte.
3. Data we process and purpose as well as legal basis
a. If you are working on the Construction Site:
- We process the Personal Data you provided in the induction request formattached in Annex 1 as well as the A1 form, which includes social insurance number, , surname, last name, birthname, date of birth, nationality, location of birth, address in state/country of habitual residence, address at the work location, start and end of the engagement, description of the engagement, whether the engagement is temporary, type of worker and the employer / contractor. The form may contain your signature and you may have to provide a copy of your ID
Furthermore, we process data about training, certificates, such as Safe Pass, VCA etc. or working at heights training etc., and security inductions you have had and results of tests at the end of such training.
The purpose of processing such personal data is to control access to and organize safety and security on our Construction Site, safeguard proper operations on the Construction Site, obtain proof and confirmation of qualification and security training, to comply with the applicable law, to keep a record of who is on site, to conduct legal and compliance investigations, where necessary, to prevent (blacklisted) persons who may pose a risk to others accessing the Construction Site, to identify who is permitted to enter the Construction Site, to establish control systems, to increase efficiency of our Construction Site, to establish an information system, to defend from and assert legal claims and to authenticate your identity.
This Processing is based on Article 6 Sec. I Lit f General Data Protection Regulation (“GDPR”), whereas it is our legitimate interest to ensure a well-organized, safe and secure Construction Site, which complies with the requirements of the law, to comply with contractual requirements of our client or to evidence work performed. It is our legitimate interest to investigate compliance and legal infringements and it is further our legitimate interest to confirm authenticity of documents and identity of persons.
We are legally required to process Personal Data for the A1 form as well as other data as listed above due to Danish law to prove that you are correctly registered as a worker in Denmark, if you are not a Danish Citizen, and we want to ensure that proper social security is extended to personnel on the Construction Site.
This data processing is based on Art 6 Sec. I Lit c) GDPR in accordance with Sec. 38 of the Danish Working Environment Act. In addition, we are processing this Personal Data based on Art. 6 Sec. I Lit f GDPR, whereas it is our legitimate interest to ensure that any person based on the Construction Site is legally entitled to work in Denmark in compliance with Danish laws and regulations, to ensure our sub-contractors are complying with applicable laws and to protect our reputation.
The processing of your social security number, where such number is considered health data, is based on Sec. 11 Para II lit 1 of the Danish Data Protection Act as on the basis that processing is necessary to carry out obligations in the field of employment, social security and social protection law in accordance with Danish law in accordance with Sec. 38 of the Danish Working Environment Act.
Please note that without processing the Personal Data above, we cannot let you enter the Construction site, which may prevent you from fulfilling your contractual obligations.
- If you are issued a personal badge, we take your picture for the purpose of identifying your badge and preventing misuse. We will also assign a badge number to your name to enable us to deactivate the badge in case of loss or theft.
The legal basis is Art 6 Sec. I Lit f GDPR with the legitimate interest to prevent misuse of the badge and identify the badge holder.
Please note that without processing the Personal Data above, we cannot let you enter the Construction site, which may prevent you from fulfilling your contractual obligations.
- We process the name and contact data of your emergency contact to inform them in case of an emergency based on your consent and to receive instructions from them, if they are eligible to make medical decisions for you.
This is based on Art. 6 Sec. I Lit a) GDPR and entirely voluntary based on your consent.
b. As visitor to the Construction Site
- If you are a visitor we process the Personal Data you included in the visitor induction form attached hereto in Annex 2. In addition we may require you to load a copy of your ID in our system with the information contained therein.
- The purpose of processing such data is to control access to and organize safety and security on the Construction Site, safeguard proper operations on the Construction Site, confirmation of qualification and security training, to keep a record of who is on site, to conduct compliance investigations, where necessary, to prevent (blacklisted) persons who may pose a risk to others accessing the Construction Site, toidentify who is entitled to enter the Construction Site, to establish control systems, to establish an information system, to defend from and assert legal claims and to authenticate your identity.
Security may look at your government issued ID to confirm your identity, but will not record information from this ID or copy the ID.
This Processing is based on Article 6 Sec. I Lit f GDPR, whereas it is our legitimate interest to ensure a well-organized, safe and secure Construction Site, which complies with the requirements of the law, to comply with contractual requirements of our client. It is our legitimate interest to investigate involvement in compliance and legal infringements and it is further our legitimate interest to verify your identity by additional means.
Please note that without processing the Personal Data above, we cannot let you enter the Construction site, which may prevent you from fulfilling your contractual obligations.
- We will also assign a visitors badge number to your name to identify the badge, which you were provided with as well as to enable us to deactivate the badge in case of loss or theft and identify you as badge holder and prevent you from re-entering in case you do not return the badge.
The legal basis is Art 6 Sec. I Lit f GDPR with the legitimate interest to prevent misuse of the badge and identify the badge holder.
Please note that without processing the Personal Data above, we cannot let you enter the Construction Site, which may prevent you from fulfilling your contractual obligations.
We process the name and contact data of your emergency contact to inform them in case of an emergency based on your consent and to receive instructions, if they are eligible to make such decisions for you.
This is based on Art. 6 Sec. I Lit a) GDPR and entirely voluntary based on your site.
c. Entering and exiting the construction area of the Construction Site
- We Process the date and time you entered and date and time you exited the administrative area and the construction area of the Construction Site.
We require this information for the safety and security of the Construction Site, to know who is and was on the Construction Site at any given time, also to find you in case of an emergency, and in case you work for a sub-contractor or are an Exyte employee in order to document working hours. Furthermore, we may Process such Personal Data for compliance investigations and in order to defend or assert legal claims and to evidence worked hours to our client.
This is based on Art. 6 Sec. I Lit f) GDPR, whereas it is our legitimate interest to have a safe and secure Construction Site, to follow-up and prevent compliance infringements, to defend against claims and being able to prove, that you were properly inducted before entering the Construction Site and how long you worked.
Please note that without processing the Personal Data above, we cannot let you enter the Construction site, which may prevent you from fulfilling your contractual obligations.
d. Information in regard to labor safety:
- We store data about medical conditions, which may be critical to safeguard your health in the event of an emergecy based on your consent in accordance with Art. 9 Sect II Lit a) GDPR. Please note that in case of emergencies we may transfer this information to first responders in accordance with Art. 9 Sect II Lit c) GDPR, if you are incapable of giving consent.
- In case you are involved in a work accident we will record the circumstances of the accident and your contact data. This may include health data as a special category of Personal Data;
The purpose is that we are required to document and file a record of the accident with the relavant authorities in order to enable you to receive insurance compensation and to assert or defend legal claims. Furthermore, we use the Personal Data to prevent future accidents , in which case we will anonymize Personal Data as soon as possible.
We are obligated to process such information and provide to the authorities according to Danish law and therefor process the Personal Data based on Art. 6 Sec. I Lit c) in conjunction with the Sect. 8 and 9 of the Executive Order on Notification of Accidents Under the Workers' Compensation Act..
We record your health data based on Art. 9 Para II Lit h GDPR i.c.w the applicable law..
Furthermore we process such data based on Art. 6 Sec. I Lit f GDPR, whereas it is our legitimate interest to prevent future accidents cf. ss. 8 and 9 of the Executive Order on Notification of Accidents Under the Workers' Compensation Act and ss. 31 and 33 of the Danish Workers' Compensation Act.
- In case you were involved in near misses (avoided work accident) we may record the circumstances and your contact data;
We record near misses for statistical purposes and to prevent work accidents in the future. We will anonymize Personal Data as soon as possible.
This is based on Art. 6 Sec. I Lit f), whereas it is our legitimate interest to prevent future work accidents.
- In case you engage in any conduct which we consider unsafe, Construction Site personnel may record a “Safe Behavior Observation” (SBO) to prevent such conduct happening in future. Personal Data collected will be minimised, where feasible, but you may be identifiable on such SBOs. We will anonymize any Personal Data as soon as possible.
This is based on Art. 6 Sec. I Lit f), whereas it is our legitimate interest to prevent future work accidents.
Please note that without processing the Personal Data above, we cannot let you enter the Construction site, which may prevent you from fulfilling your contractual obligations.
e. Other circumstances
- If you are working on the Construction Site, we may sort and forward hard copy mail addressed to youbased on the name and address on the envelope (we do not open the envelope);
The purpose is to provide you with required information from mail.
This is based on Art. 6 Sec. I Lit f), whereas it is our legitimate interest to organize communication on the Construction site.
- If you are working on the Construction Site we keep your contact data in organizational trees and other organizational, tool safety lists and instructive documents as well as in control systems and contact lists in order to effectively, safely and securely organize our Construction Site.
This is based on Art. 6 Sec. I Lit f), whereas it is our legitimate interest to effectively and smoothly organize the construction site.
- If you are a first aid helper, fire defense specialist or otherwise undertaking any importantsafety role, we will publish your contact data on the Construction Site.
The purpose is to get help as soon as possible in an emergency.
This is based on Art. 6 Sec. I Lit f), whereas it is our legitimate interest to organize communication on the Construction site.
.4. Source of the Personal Data
Most Personal Data is collected from you directly (e.g. through the forms) and through the gates when entering our Construction Site with a badge.
5. Transfer of Personal Data
Generally, on the Construction Site, data is not shared with third parties.
We may share your name, position, employer and reason for visit with the Danish Working Environment Authority (DWEA) representatives to safeguard our business.
This processing is based Art 6 Sect. I Lit f) GDPR, whereas it is our legitimate interest to ensure a secure site and comply with our contractual agreements with our client as well as the client’s legitimate interest to protect their assets.
We engage service providers for technical infrastructure and software (e.g. cloud providers) to store data for us. We conclude processing agreements and /or non-disclosure agreements with such service providers to safeguard your data. These service providers are only permitted to process Personal Data for us for the purpose they are engaged.
We may transfer Personal Data between Exyte affiliates within the Exyte Group based on our legitimate interest according to Art. 6 para. I lit. f GDPR or other legal reasons, where they apply, whereas our legitimate interest is to organize the company group centrally and provide services within group service centers as well as to have the processing allocated to the most suitable group member for further interaction with the data subject.
All group members are subject to a Data Protection Policy to ensure a constant level of data protection.
Some Exyte Group members may be located outsider the European Economic Area (“EEA”) in countries for which the European Commission (“EC”) did not decide that such countries provide an adequate level of data protection.
All Exyte Group members therefore signed a Data Processing and Joint Controller Agreement (“DPJCA”) which includes the standard contractual clauses as approved by the EC to safeguard the processing of Personal Data outside the EEA, i.e. all Exyte Group members are contractually obligated to comply with an adequate data protection level.
Please find a list of all Exyte entities belonging to the Exyte Group under this link.
Beside the transfer within the Exyte Group a transfer of Personal Data to third parties does not take place, with the exception of:
-Transfer with your express permission (Art 6 para. I lit a GDPR or Art 9 para II Lit a GDPR);
-Transfers to third parties to which we are legally obliged, for example to the tax office or other governmental authorities, according to Art. 6 para I lit c GDPR, Art 9 para II lit b or lit h) GDPR;
-Transfers to third parties to fulfill our commercial and tax obligations, for example to our tax auditor according to Art. 6 para I c GDPR i.c.m with the respective individual obligation, if we are legally obliged to transfer such data or Article 6 para I f GDPR, if the transfer is not mandatory, but required for our legitimate interest to efficiently communicate and proceed with authorities and comply with our obligations.
-In order to conduct or assist with investigations into breach of laws or compliance regulations, assert legal claims or to defend against legal claims we may transfer data to authorities or to lawyers, agents, experts etc. based on Art. 6 para I lit f GDPR, whereas it is our legitimate interest to assert or defend from legal claims. In case of special categories of Personal Data we may transfer such data based on Art. 9 para II lit f GDPR to assert or defend against a legal claim.
Any transfer of data to a third country outside the EU, which is also not a party to the EEA, will only take place if such transfer of data is necessary for the purpose and always subject to requirements in compliance with the GDPR.
6. Duration of processing
We will process your Personal Data for the time only, which is necessary to complete the purpose for which it was collected.
For visitors, that may be until the end of the project and one year in addition.
Social security and employment data usually is kept for 5 years to comply with social security obligations.
We may however have to retain your Personal Data for longer in case of legal obligations (e.g. a tax audit) or to defend or assert a legal dispute or delete them earlier if legally feasible and practical.
7.No automated decision making
We do not base decisions which have legal implications for you solely on automated decision making, such as profiling.
8. Your rights
Upon request we will inform you whether Exyte processes any Personal Data about you, and if so, the nature of such Personal Data.
If we process your Personal Data in order to advertise, you have the right to object to the processing of your Personal Data for the purpose of advertising at any time. If you object to the processing for purposes of advertising, your Personal Data will no longer be processed for this purpose.
The easiest method to object to advertisement is to send an email to info@exyte.net. However, we accept any other form of objections to advertisement, which allows us to clearly identify you.
Furthermore, based on your particular situation, you have the right to object against processing of your Personal Data which is processed based on Article 6 para. I lit. f GDPR, i.e. legitimate interest, or Art 6 para. I lit e GDPR, i.e. processing based on necessity for the performance of a task carried out in the public interest or in the exercise of official authority vested in Exyte. In case you object to processing based on the aforementioned legal basis due to your particular situation, we will only continue to process the information if there are compelling legitimate grounds to process your Personal Data which override your interest, rights or freedoms to stop processing your Personal Data or for the exercise or defense of legal claims. This also applies to profiling based on the aforementioned.
Under the conditions as set out in the GDPR, according to Art. 16 GDPR you also have the right to correct your incorrect or incomplete Personal Data as well as a right to deletion according to Art. 17 GDPR and a right to restrict the processing of your Personal Data under Art. 18 GDPR.
You also have the right to receive from us Personal Data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format. You have the right to transmit (or have transmitted) the Personal Data to another controller.
If the processing of Personal Data concerning you is based on your consent, you have the right to revoke your consent at any time. The lawfulness of the processing on the basis of the consent until the revocation is not affected.
You also have the right to lodge a complaint with the competent supervisory authority for data protection matters. Unless stated otherwise, the competent authority is the “Data Protection Commissioner / An Coimisinéir Cosanta Sonraí” in Dublin, Irelamd.
As data subject you can also contact the authority responsible for the Construction Site location, which is the Danish Data Protection Agency / Datatilsynet, in Copenhagen Denmark.
Annex 1: Induction Form
Project: |
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PartOne–PersonnelDetails* |
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FullName |
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PermanentAddress |
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JobTitle |
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Phonenumber |
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TemporaryAddress (if any) |
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Nationality |
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Social Sec. No. |
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PassportNo.** |
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IDCard No.** |
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Validuntil |
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A1Form |
Yes/No (copyrequired) (A1not requiredfor Danish residents) |
Validuntil |
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Part Two–EmployerDetails |
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NameofEmployer (whopays you) |
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AddressEmployer |
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NameofContractor (ifnotEmployer) |
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Job/Position |
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BusinessphoneNo. |
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CompanyRegistration Number |
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SelfEmployed |
Yes/No |
Contact nameEmployer |
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SelfEmployedReg.No. |
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PhoneNo. Employer |
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PartThree–Emergency contact (voluntary) |
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Name |
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Relationship |
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ContactPhoneNo. |
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By entering the information you consentto us processing the emergency contact information according to our data protection information notice, which you can find at the link below, under the QR-Code or which you can obtain at the Security office in paper form. You also confirm that you have obtained the consent of the emergency contact persons, informed them accordingly and have their permission to consent to our processing. You can revoke your consent at any time by contacting privacy@exyte.net |
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PartFour–Competence-Trainingrequirements(evidencerequired)**** |
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SafePass/CSCSCard No. |
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SafePass/CSCS CardExpiry Date |
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SCCCardNo |
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SCCCardExpiryDate |
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Please selecttraining completed(copyrequired) |
OManualHandling OWorkingatHeights OAbrasiveWheel (Copy of training required) OScaffolder (Cert required) ORigger (Copy of training required) OMobile Tower Scaffold (Copy of training required) |
OConfinedSpace (Copy of training required) OFirstAid (Cert required) OSlinger/Signaler (Copy of training required) OCrawler Crane (Cert required) OExcavator operator (Copy of training required) |
OMEWP (copy of IPAF required) OTelehandlerOperator (Cert required) OMobileCrane Operator (Cert required) OSelf Erecting Tower Crane Operation (Cert required) OForklift Operator (Copy of training required) ODozer operator (Copy of training required) |
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Part Five–Inductiondetails(Detailedinductionprocedureonthenextpageofthisform.) |
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E-mail address |
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Contactperson/translator |
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Phonenumber: |
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PartSix –Healthdeclaration |
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Ifyouaretakinganymedication orhaveanymedicalconditionsthatyoubelieveyou shouldinformusof, pleaseenter those here.
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Please note that this information is voluntary and you provide your express consent by filling these information into the form. Please find more information in our data protection information, which you can find at the link below, under the QR-Code or which you can obtain at the security hut in paper form. You can revoke your consent at any time by contactingprivacy@exyte.net [Link] |
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Part Seven–Inductiondetails(Detailedinductionprocedureonthenextpageofthisform.) |
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E-mail address foronlineInduction |
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PartEight–GDPRIformation |
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Please note that we collect your information based on various laws and for various purposes and that you have specific rights in regard to your personal data.
Among others, Exyte must comply with certain employment and health & safety legislation and so relies on the lawful basis of compliance with a legal obligationunder Article 6(1)(c) of the GDPR. You will find further information on the detailed obligations in our data protection declaration below.
Exyte relies on Article 9(2)(b) of the GDPR on the basis that processingisnecessary to carry out obligations in the field of employment, social security and social protection law. In particular, Exyte must comply with Danish Legislation governing employment and, in compliance with the project Industrial Relations Strategy document, data such as employment contracts, payslips and timesheets must be available and provided to the authorities upon request during Compliance spot checks (collectively referred to as “Employment Data”); You will find further information on the detailed obligations in our data protection declaration below.
For any other special category data contained on or provided by you, Exyte relies on Article 9(2)(h) of the GDPR which permits processing for the provision of preventative or occupational medicine, medical diagnosis or health care or treatment. You will find further information on the detailed obligations in our data protection declaration below.
[Link]
You will find additional details and all legally required information under this link or if you scan the following QR Code. You may also request a hard copy at any time at the security hut on site.
If you have any questions, complaints or suggestions, please contact us at privacy@exyte.net Your information is saved in a secured environment with restricted access. Your information may be shared with third parties including authorities and other Exyte Group members for the purposes of Exyte complying with its legal obligations and in the event that you require medical treatment or care, for compliance investigations in case of breach of laws, our code of conduct, contractual agreements or other regulations as well as to assert or defend from claims. When we share your personal data with third parties, we put in place appropriate measures to limit the use of your personal data only for legal and authorized purposes, as well as appropriate confidentiality and security measures. We store and process your data for the purposes described above only for as long as it is necessary, which usually is to the maximum of five years in accordance with Danish legislation to fulfil these purposes or as needed to comply with legal obligations. We will securely delete or destroy any personal data when we no longer need it for these purposes. You have the right to enquire about the personal data we keep about you and exercise your rights of access, correction, restriction, objection and deletion in accordance with Art 15 ff. General Data Protection Regulation (EU 2016/679). If you would like to exercise any of these statutory rights, please contact privacy@exyte.net.
If you have any queries in relation to your personal data or this policy, you can contact the Exyte Group Data Protection Officer by e-mail via:privacy@exyte.net.
** A copy of your passport/ID is required to be provided or can be visually shown to Exyte or Security team and details noted on access control system. A residence/work permit will be required if you are not an EU citizen. if
***Thisinformationwillonly beused incaseofan emergency.Thisinformation willbestoredina securedenvironmentwith restricted access. Your information will not be saved or shared for anotherpurpose.
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Part Eight–InductionProcedure |
The complete induction procedure has several steps that you need to follow and complete before going to site.
Complete this form in Word and submit this to your Project Administrator at least 48 hours before starting on site. Based on the form, the information will be input to the site Access Control system to proceed with printing access badge for site.
MandatoryTrainingtoenter project:
ForData Protection Reasons we recommend to send the A1 Form and this Form encrypted only. Our operative will send you an encrypted email to which you can reply encrypted.
All operatives must wear 5-point PPE (Ankle support safety boots, Hardhat,highVizvest/jacket,gloves&safetyglasses) provided by your employer. No safety shoes or rigger boots are allowed.
NOTE: If the mandatory training records are not submitted prior to coming to site, you willnotbeallowedtocompletetheinduction.
Noexemptionswillbemade |
FullName: SignName: Date: |
Annex 2: Visitor Form
Site Name: |
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Contract No: |
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Site Visitors Name: |
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Company Name: |
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Site Visitor’s Home Address: |
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Emergency Contact Name: |
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Contact No: |
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By entering the information you consentto us processing the emergency contact information according to our data protection information, which you can find at the link below, under the QR-Code or which you can obtain at the Security hut in paper form. You also confirm that you have obtained the consent of the emergency contact persons, informed them accordingly and have their permission to consent to our processing. You can revoke your consent at any time by contacting privacy@exyte.net |
Site Safety Management – Identify points covered by induction by ticking the box |
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Exyte site management team familiarisation. |
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Upon completion of this form the site visitor will sign the visitor induction register. |
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The Site visitor must always be escorted by an Exyte or Contractor representative. |
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Access restrictions – site visitors and operatives to remain within the site perimeter fence at all times while visiting this site. |
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PPE – All visitors are required to wear Hard Hat, Gloves, Safety Glasses, Hi Visibility vest and protective boots at all times whilst on this site. |
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All statutory notices must always be obeyed. |
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First Aid arrangements to be advised by the escort. |
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Any accidents, hazards or near misses must be reported to the site escort. |
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Welfare arrangements – No eating on site. Site facilities are to be kept clean and tidy. |
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Site vehicles, plant and equipment only to be operated by authorised personnel. |
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Smoking, drinking alcohol and the taking of non-prescription drugs are not permitted on site. Designated smoking location to be advised to the site visitor. |
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Upon hearing the emergency alarm, the site visitor will be escorted to the site muster point, there will be a site roll call, thereafter the site visitor will be advised when it is safe to return into the building. |
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Please identify any issues to your escort during the visit. |
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To be completed by the person receiving the site visitor’s induction |
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Has the Exyte escort fully explained the safe terms of the site visit? |
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Do you understand the above points relating to the site visit and agree to comply with them? |
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Please state in the box below any disabilities, medical conditions, illness and whether you are taking any prescribed medication that you wish Exyte to be made aware of: |
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Please note that this information is voluntary and you provide your express consent by filling these information into the form. Please find more information in our data protection information, which you can find at the link below, under the QR-Code or which you can obtain at the Security Hut in paper form. You can revoke your consent at any time by contacting privacy@exyte.net [Link]
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If the answer is ‘No’ to questions 14 and 15 then entry to the working site areas will not be permitted by the Exyte Site Management |
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Visitors Signature: |
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Instructors Full Name: |
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Signature: |
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Date: |
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