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Privacy policy
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Scripts and page chrome removed; this is what change detection compares.

                                         2024

Privacy Policy
(GDPR)

                 Administered by: HR Department
                  Approved by: CEO Logent Group
                          Valid from: 2024-02-06
                   Valid until: Until further notice
    1. Purpose and scope
This privacy policy explains how Logent processes personal data about you as an employee (including
former employees), consultant/temporary staff and job applicant in connection with recruitment,
employment and related processes. This policy is an information notice under the GDPR and is
supplemented by internal governing documents and procedures (e.g. retention schedule, information
security procedures, access management and the CCTV Policy where camera surveillance is used).

    2. Controller, contact details and Data Protection
       Officer (DPO)
The company within the Logent group that is your employer (or that is responsible for the relevant
recruitment process) is the controller for the processing. In some cases, group-wide functions or
several companies may be joint controllers (e.g. for shared IT/HR processes). Upon request, you can
receive more information about which company is responsible in a specific case.

Contact for data protection matters: it@logent.se

Postal address: Hammarby Kaj 14, 120 30 Stockholm – Attention GDPR.

Data Protection Officer (DPO): Logent has currently not appointed a Data Protection Officer. Data
protection matters are handled via the contact details above.

    3. Which personal data we process
Depending on your role and situation, we may process the following categories of personal data:

•   Identity and contact data (e.g. name, national ID number, address, phone number, email).
•   Employment and assignment data (e.g. job title, type of employment/assignment, start/end date,
    organisational unit).
•   Salary and benefits data (e.g. salary, allowances, benefits, bank details, tax data).
•   Time and absence data (e.g. schedule, time reporting, leave, absence codes to the extent required).
•   Work environment/rehabilitation (limited health data where required by law/agreements, e.g.
    certificates and rehabilitation measures).
•   IT and security data (e.g. access rights, access logs, device information, incident data).
•   Business communications (e.g. email, Teams, case handling, to the extent needed for work).
•   Data in connection with investigations, incidents and disputes (e.g. employment law matters,
    disciplinary measures).
•   Recruitment data (e.g. CV, application, interview notes, references).
•   Image/video/audio (e.g. photo for access card or intranet; where applicable
    communications/marketing).
•   CCTV footage (where camera surveillance is used in the business).

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      4. Where does the data come from?
We process personal data only when we have a clear purpose and a lawful basis under the GDPR. The
most common sources are:

•     You (e.g. when you apply for a job, during onboarding, in HR/self-service systems).
•     Your manager/HR and other internal functions (e.g. for scheduling, payroll, access
      administration).
•     External parties where relevant and permitted (e.g. authorities, benefit providers, occupational
      health services, references in recruitment).
•     Systems and logs generated through the use of IT systems, access systems and security solutions.

      5. Why we process personal data and lawful basis
We process personal data only when we have a clear purpose and a lawful basis under the GDPR. The
most common lawful bases in an employment context are:

•     Contract – processing is necessary to perform the employment contract or to take steps prior to
      entering into a contract.
•     Legal obligation – e.g. tax, accounting, work environment and employment law requirements.
•     Legitimate interests – e.g. access administration, IT security, internal communication, operational
      and quality follow-up, and to establish, exercise or defend legal claims.
•     Consent – used restrictively in working life and only where consent can be genuinely voluntary
      and can be withdrawn without negative consequences.

Examples of common processing activities (overview):

    Purpose                    Examples                   Lawful basis            Retention
                                                          (typical)               (principle)
    Employment and payroll     Salary, allowances,        Contract / Legal        During employment
    administration             taxes, pension and         obligation              and thereafter as
                               benefits administration,                           required by law and
                               reporting.                                         the retention
                                                                                  schedule (e.g.
                                                                                  accounting).
    Time reporting and         Scheduling, time bank,     Contract / Legal        According to
    staffing                   absence, planning,         obligation /            collective
                               staffing follow-up.        Legitimate interests    agreements/law and
                                                                                  the retention
                                                                                  schedule.
    Access rights, IT and      Access provisioning,       Legitimate interests    As long as needed for
    security                   logs, device               / Legal obligation      security and follow-
                               management, incident                               up according to the
                               management.                                        retention schedule.
    Work environment and       Work environment           Legal obligation /      Limited retention
    rehabilitation             measures, rehabilitation   (special categories,    according to legal
                               plan, occupational         see section below)      requirements and
                               injury, contact with                               retention schedule;
                               occupational health                                strict access controls.
                               services.
    Recruitment                Selection, interviews,     Legitimate interests    Limited time after
                               references, background     / Contract (pre-        completion
                               checks where justified.    employment)             according to

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                                                                                    recruitment
                                                                                    procedure.
    Investigations, incidents   Investigation of             Legitimate interests   As long as the case is
    and disputes                incidents, disciplinary      / Legal obligation     ongoing and
                                matters, whistleblowing                             thereafter with
                                (if applicable), disputes.                          regard to limitation
                                                                                    periods and the
                                                                                    retention schedule.
    Internal communication      Contact lists, intranet,     Legitimate interests   During employment
    and organisational          internal news,                                      and thereafter for a
    information                 organisational data.                                short period
                                                                                    according to the
                                                                                    retention schedule.

      6. Special categories of personal data (e.g. health)
Certain personal data is particularly sensitive ("special categories"), such as health data. Such data is
processed only when necessary and lawful, for example to meet obligations in employment and work
environment law, handle rehabilitation or occupational injuries. Access to such data is strictly limited
(need-to-know) and protected by enhanced security measures.

      7. Whether you must provide data and consequences
Some data is needed to enter into and perform an employment contract (e.g. contact details and bank
details), and other data is needed to comply with legal obligations (e.g. national ID number and data
required for tax and work environment reporting). If you do not provide necessary data, this may
mean that we cannot administer your employment, pay salary, or grant access to systems and the
workplace.

      8. Recipients, processors and disclosures
We may share personal data with:

•     Processors that process data on our behalf (e.g. HR/payroll systems, time reporting systems, IT
      operations, recruitment systems, occupational health services).
•     Independent controllers (e.g. authorities, banks, insurance companies, pension providers).
•     Group companies and group-wide functions where required for administration, security or
      compliance.

When we engage processors, we enter into data processing agreements and require security,
confidentiality and controls regarding sub-processors. Disclosures to third parties take place only
when there is a lawful basis, e.g. a legal obligation or legitimate interests (for example in investigations
of crime or incidents).

      9. Transfers outside the EU/EEA
If personal data is transferred to countries outside the EU/EEA (e.g. through cloud services or group-
wide IT), we ensure that the transfer has a lawful basis, for example through the European
Commission’s Standard Contractual Clauses (SCC) a             nd supplementary safeguards where
required (e.g. a transfer impact assessment (TIA)).

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    10.        Retention and deletion
We keep personal data as long as it is needed for the purposes and in accordance with applicable legal
requirements. Thereafter, data is deleted or anonymised in line with Logent’s retention schedule.
Different data types have different retention requirements. Examples:

•   Documentation subject to accounting rules may need to be retained for several years (under
    applicable law).
•   Data in dispute and investigation cases is retained as long as justified with regard to the nature of
    the case and limitation periods.
•   IT security logs are normally retained for a limited period and in accordance with security and
    incident procedures.

Detailed retention periods are set out in Logent’s retention schedule: M:\Verksamhetssystem\12.
Chefshandbok - NY (uppdateras löpande)\11. GDPR – Personaldokument.

    11.        Automated decision-making and profiling
Logent does not use automated decision-making that produces legal effects concerning you, or
similarly significantly affects you, based solely on automated processing, unless otherwise stated in
specific information for a particular process (e.g. recruitment). If such processing were to occur, we
will provide specific information, including the logic involved and your rights.

    12.        CCTV (camera surveillance)
In some operations, Logent may use camera surveillance for security and safety purposes, for example
to prevent, detect or investigate crime or serious incidents. Camera surveillance is never used for the
purpose of routinely monitoring employees’ work performance.

From 1 April 2025, new rules apply to camera surveillance. In summary:

•   No one needs to apply to IMY for a permit to conduct camera surveillance.
•   Actors that previously required a permit must carry out their own balancing test between the
    surveillance interest and the individual’s interest in not being monitored.
•   The balancing test must be documented. Logent also documents assessments as part of GDPR
    accountability.
•   Where required, the party conducting camera surveillance must also keep a record with certain
    information about the surveillance carried out, or that has ceased within the last five years. As part
    of GDPR accountability, Logent documents and retains information about ceased camera
    surveillance in the record for up to five years.

Camera surveillance is regulated in more detail in Logent’s CCTV Policy, which, among other things,
describes placement, signage and supplementary information, retention periods, access and logging,
disclosures (e.g. to law enforcement authorities), incident handling and templates for the balancing
test and record. The policy also states that surveillance must not take place in areas where the privacy
intrusion is normally particularly significant (e.g. changing rooms and break areas) and that audio
recording is normally not used.

Requests for access to CCTV footage are handled via Logent’s data protection contact. Logent may
need to verify identity and narrow the request (e.g. time and location). Where footage includes other
individuals, their privacy is protected through measures such as masking/redaction or limiting

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disclosure. In complex cases or where there is uncertainty, the matter is escalated to the Legal/DPO
function in accordance with internal procedures.

    13.       Your rights
Depending on the circumstances, you have the following rights:

•   Right to information and access (data subject access request).
•   Right to rectification of inaccurate data.
•   Right to erasure in certain cases.
•   Right to object to processing based on legitimate interests.
•   Right to restriction of processing in certain cases.
•   Right to data portability where processing is based on contract or consent and is carried out by
    automated means.
•   Right to withdraw consent (where processing is based on consent) without affecting the lawfulness
    of processing before withdrawal.
•   Right to lodge a complaint with the Swedish Authority for Privacy Protection (IMY).

To exercise your rights, contact: it@logent.se. We may need to verify your identity. We normally
respond without undue delay and at the latest within one month, unless an exception applies.

    14.       Security and incidents
Logent works systematically with information security. We use technical and organisational measures
such as access controls, logging, backups, encryption where appropriate, training and incident
management procedures. Personal data breaches are handled in accordance with internal procedures
and reported to IMY when required.

    15.       Changes to this policy
We may update this policy as needed, for example when processes, systems or regulations change. In
the event of material changes, we will inform affected parties.

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