People Privacy Notice

Introduction

The Radius Group consists of multiple companies (legal entities). The company responsible for the processing of your personal data is dependent on the purpose for which your personal data is collected. This privacy notice relates to the below legal entities:

• Radius Connect Limited
• Radius Insurance Solutions Limited
• Radius Telematics Limited
• Radius Vehicle Solutions Limited
• Radius Vehicle Solutions NI Limited
• GUS Commercials Limited
• UK Fuels Limited
• Radius Velos Limited
• Adam Phones Limited
• Traction Finance

For this privacy notice UK Fuels Limited, Radius Campus, Emperor Way, Crewe Business Park, Crewe, CW1 6BD is the main entity processing personal data.

For each specific processing purpose, you will be informed which entity is responsible for processing your personal data.

Radius (“Radius,” “we,” “our,” or “us”) holds and processes data on all current and former colleagues, workers, individual contractors, contingent workers, applicants, interview candidates, interns, agency workers, consultants, directors, members (i.e. partners), and third parties whose information you provide to us in connection with the employment relationship (e.g. next-of-kin, emergency contact information and/or dependents) (“staff” or “you” or “your”).

We take your data protection rights and our legal obligations seriously. Your personal information will be treated in a secure and confidential manner and only as set out below.

The following Privacy Notice describes the categories of personal information we may process, how your personal information may be processed and how your privacy is safeguarded during our employment relationship with you. It is intended to comply with our obligations to provide you with information about Radius's processing of your personal information under privacy laws.

When can we process your personal data?

We will only collect, process, use or store personal data if we have valid and lawful reasons to do so. Your personal data may be processed by us based on reasons derived from the following factors:

Contract: When you are considering, or have been offered employment, we will process your personal data necessary for fulfilment of a contract (such as your employment contract) with you and to fulfil any obligations derived from that contract.

Legitimate Interest: We may process your personal information when necessary for our legitimate interests and when these interests do not outweigh your own rights and interests. Legal requirement: We may process your personal data where necessary to comply with applicable laws. If you are seconded or transferred to work in another country, this may include processing your personal data to meet local employment, tax, immigration, social security, or regulatory requirements.

Consent: When you give us your consent, we will process your personal data for the specific purpose you have consented to. For each specific purpose of processing of personal data, we will inform you about which of the above justifications will apply.

Special categories of personal data

To the extent permitted by applicable laws, or with your consent, Radius may also collect and process a limited amount of personal information falling into special categories, sometimes called “sensitive personal data.”

Processing of dependent information

Radius may collect and process personal data relating to a colleague's dependents where such information is necessary for employment-related purposes, including administering colleague benefits, insurance coverage, leave entitlements, emergency contacts, relocation services, travel arrangements, or other employment-related programs and services involving dependents.

Radius will only process dependent personal data where:

• the personal data has been provided by the colleague or dependent with appropriate consent, or where consent cannot reasonably be obtained and processing is necessary to protect the vital interests of the colleague, dependent, or another individual;
• the processing is reasonably necessary to administer, perform, or support the colleague's employment relationship or contract, including providing benefits or services that extend to the colleague's dependents; or
• the processing is required or permitted under applicable law.

Who is responsible for this processing, what is the legal basis, and how long do we keep it?

Unless stated otherwise for a specific processing activity below:

• UK Fuels Limited is a joint data controller with your recruiting entity for all the processing activities described in this notice.
• We process your personal data on the bases set out above (see ‘When can we process your personal data?’) — typically because it is necessary for the performance of your contract, for our legitimate interests, or to comply with a legal requirement. Where processing is not based on one of these grounds, we rely on your consent.
• We will keep and process your personal data no longer than is necessary for us to perform our contractual or legal obligations as your employer or prospective employer.

Where a specific processing activity below relies on a different controller, legal basis, or retention period, this is noted under that activity.

How do we process your personal data and why?

We have identified the following purposes for processing personal information. These purposes each relate to a lawful basis for processing, as required under applicable law.

We may use Artificial Intelligence (AI) technologies when processing personal data in connection with our People activities and services. Where AI is used, we will do so responsibly and in accordance with applicable data protection laws. We maintain appropriate oversight of AI-supported processes and, where required, will provide information about the use of AI in relation to personal data processing.

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For each processing activity, the following sections outline the purpose of the processing and the categories of personal data involved.

Recruitment and Selection

Processing Activity

To process your request to enter a contract of employment.

To undertake appropriate vetting for recruitment and team allocation including reports from the DBS.

Type of Personal Data

Personal Identifiers:

• Title, forename, middle name(s) and surname
• birth name
• gender
• nationality
• date of birth
• home contact details (e.g. address, telephone number, e-mail)
• national ID number

These often remain the same and are listed as “Personal Identifiers” for the remainder of this document.

Other personal information:

• immigration and eligibility to work data
• job title and job description
• working hours and patterns
• references
• qualifications
• CV and application
• interview and assessment data
• vetting and verification information
• where required, health information to support workplace adjustments

Further information: Radius collects and records your personal information from a variety of sources, but mainly directly from you. We may also obtain some information from third parties, for example, references.

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General Employment

Processing Activity

Providing and administering remuneration, incentive schemes and making appropriate tax and social security deductions and contributions.

Managing and operating appraisal, conduct, performance, capability, absence and grievance related reviews, allegations, complaints, investigations and processes and other informal and formal People Team processes and making related management decisions.

Consultations or negotiations with representatives of staff.

Make adjustments or accommodations to duties or the workplace; make management decisions regarding employment or engagement or continued employment or engagement or redeployment; and conduct related management processes.

To support People Team administration and management and maintaining and processing general records necessary to manage the employment, worker or other relationship and operate the contract of employment or engagement.

Management and investigation of any complaint under Radius's grievance policy (or other relevant policies), where such characteristics or information are relevant to the complaint, to comply with employment law obligations.

Types of Personal Data

• Personal Identifiers

Other work identifiers:

• time zone and currency for location
• colleague ID and various system IDs
• performance review information
• work biography
• reporting line
• colleague/contingent worker type
• hire/contract begin and end dates
• cost centre
• job title and job description
• working hours and patterns
• termination/contract end date
• reason for termination
• last day of work
• exit interviews
• references
• status (active/inactive/terminated)
• position title
• reason for any change in job and date of change
• salary/hourly plan/contract/commission pay information
• allowance
• bonus and merit plans
• bank account details
• tax information
• absence records (including dates and categories of leave/time-off, medical notes, letters, occupational reports)
• medical information related to absence (doctors notes, medical letters, occupational health reports)
• return to work interviews
• holiday dates
• family leave
• concerns
• reports
• complaints
• grievances
• matters raised, investigations and proceeding records and outcomes
• colleague and manager feedback and appraisals
• formal and informal performance management processes
• flexible working processes
• restructure and redundancy plans
• consultation records
• selection and redeployment data
• health and safety audits
• risk assessments
• incident reports
• next-of-kin / dependent contact information

Further information: We will tell you when information is mandatory. If you do not provide it, we may be unable to complete People processes (e.g. pay you), and it could affect your employment or engagement.

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Employment Business Activities

Processing Activity

Allocating and managing duties and responsibilities and the business activities to which they relate, including business travel.

Identifying and communicating effectively with staff.

Conducting surveys for benchmarking and identifying improved ways of working and colleague relations and engagement at work (these will be anonymous but may include profiling data such as age to support analysis of results).

For planning, managing, and carrying out restructuring or redundancies or other change programmes including appropriate consultation, selection, alternative employment searches, and related management decisions.

Operating email, IT, internet, social media, People Team related and other company policies and procedures. To the extent permitted by applicable laws, Radius carries out monitoring of Radius's IT systems to protect and maintain the integrity of Radius's IT systems and infrastructure; to ensure compliance with Radius's IT policies and to locate information through searches.

Protecting the private, confidential, and proprietary information of Radius, its colleagues, its clients and third parties.

Where relevant for publishing appropriate internal or external communications or publicity material including via social media in appropriate circumstances.

Protecting premises and physical assets.

To change access permissions.

To provide technical support and maintenance for People Team information systems.

To develop innovative products, e.g. Telematics systems.

Types of Personal Data

• Personal Identifiers

Other work identifiers:

• work location
• reporting line
• cost centre
• job title
• position title
• salary/hourly plan/contract pay
• allowance
• bank account details
• closed circuit television footage
• system and building login and access records
• keystroke, download and print records
• call recordings
• data caught by IT security programmes and filters
• location data
• driving data
• registration plate
• driving behaviours
• IP adress
• Photographs
• Video footage

Further information: Data may be collected indirectly from monitoring devices or by other means (for example, building and location access control and monitoring systems, closed circuit television, telephone logs and recordings and email and internet access logs).

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Colleague Benefits

Processing Activity

Providing and administering benefit schemes, including:

• EV Charge Point
• Colleague Fuel Card
• BUPA Health Care
• EV Car Scheme
• Pension
• Death in Service
• Help@Hand

Types of Personal Data

• Personal Identifiers

Other work identifiers:

• work location
• cost centre
• position title
• salary/hourly plan/contract pay
• allowance
• colleague/contingent worker type
• next-of-kin/dependent contact information
• registration plate

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Training and Development

Processing Activity

Training, development, promotion, career and succession planning and business contingency planning.

Quality assurance and training for customer service activities.

Type of Personal Data

• Personal Identifiers

Other work identifiers:

• training and development needs
• training received
• call recordings
• screen recordings
• work location
• cost centre
• position title
• reporting line
• logged on sheets
• insights training
• performance review information
• formal and informal performance managment
• colleague and manager feedback
• default language
• time zone and currency for location
• talent programmes and assessments
• leadership capability assessments
• talent or succession plans

Further information: Radius will invest in its workforce to ensure it is operating to its optimal level. This includes ensuring that each colleague undertakes appropriate duties, are trained and undertake their roles correctly and in accordance with appropriate procedures.

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Regulatory Obligations

Processing Activity

Supervise individuals acting on its behalf, including preventing, detecting, and investigating activities or behaviours across business operations and the workplace, and liaising with regulators in line with applicable laws.

Comply with SMF, FCA and any other regulatory requirements.

Comply with applicable laws and regulations, including employment, tax, health and safety, working time, leave, and consultation requirements.

Plan, assess, and implement commercial transactions or service transfers (e.g. mergers, acquisitions, or employment transfers) that affect the relationship with Radius.

For business operational and reporting documentation such as the preparation of annual reports.

Manage relationships with third-party suppliers, including sharing necessary vetting, identification, and professional information with clients and processors to support service delivery.

To enforce our legal rights and obligations, and for any purposes in connection with any legal claims made by, against or otherwise involving you.

To comply with lawful requests by public authorities whether within or outside your country.

Type of Personal Data

• Personal Identifiers

Other personal information:

• immigration and eligibility to work data
• job title and job description
• CV
• hire/contract begin and end dates
• salary/hourly plan/contract pay
• allowance
• bonus (merit plans)

Other work identifiers:

• work contact details (e.g. address, telephone number, e-mail)
• work location
• worker ID and various system IDs
• job title and job description
• position title
• health and safety audits
• risk assessments
• tax information
• working hours and patterns
• absence records (including dates and categories of leave/time-off_
• holiday dates
• family leave
• concerns
• reports
• complaints
• grievances
• matters raised
• investigations and proceedings records and outcomes
• incident reports
• closed circuit television footage
• vetting and verification information

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Who may access your personal data

Personal information within Radius is accessed on a need-to-know basis by:

• The People Team, managers, and relevant decision-makers;
• System administrators;
• Staff in teams such as Finance, IT, and People for specific tasks or system maintenance.

Basic details (e.g. name, role, location, contact information, and skills) may be visible to other colleagues.

Your data may also be shared with trusted third parties (e.g. payroll providers, IT system providers, and their subcontractors) to support services such as system hosting and maintenance. It may also be shared with integrated systems (e.g. recruitment, payroll, and benefits platforms).

Examples of third parties include tax and regulatory authorities, insurers, banks, auditors, lawyers, consultants, medical professionals (where required), and benefits administrators. These parties are expected to handle data in line with legal requirements, including confidentiality and security.

Where third parties act as data processors, they only process data on Radius's instructions and to the extent necessary.

Personal information may also be disclosed to authorities where required to comply with legal obligations, such as audits or legal proceedings.

A list of third-party processors is available on request.

Security of data

Radius uses a variety of technical and organisational methods to secure your personal information in accordance with applicable laws.

Radius is committed to protecting the security of the personal information you share with us. In support of this commitment, we have implemented appropriate technical, physical and organisational measures to ensure a level of security appropriate to the risk. Further information is available here.

What are your privacy rights?

Data protection is a fundamental right. Under applicable data protection laws, you have several rights relating to your personal data. These rights are:

Right to access: You have the right to request information about the personal data we hold about you at any time.

Right to portability: Whenever we process your personal data, by automated means based on your consent or based on an agreement, you have the right to get a copy of your data transferred to you or to another party. This only includes the personal data you have submitted to us.

Right to rectification: You have the right to request rectification of your personal data if the information is incorrect, including the right to have incomplete personal data completed.

Right to erasure: You have the right to request erasure of your personal data processed by us at any time. Your personal data may continue to be processed under certain circumstances. We will fully erase your personal data once it is no longer necessary for the purpose for which we originally collected or processed it, or when we are no longer legally required to process it.

Right to restriction: You have the right to request that we restrict the processing of your personal data under the following circumstances:

• if you object to a processing based on our legitimate interest, we will restrict all processing of such data pending the verification of the legitimate interest;
• if you have claimed that your personal data is incorrect, we must restrict all processing of such data pending the verification of the accuracy of the personal data;
• if the processing is unlawful, you can oppose the erasure of personal data and instead request the restriction of the use of your personal data;
• if we no longer need the personal data but it is required by you to defend legal claims.

Right to withdraw your consent: For each processing purpose you have given us your consent, you have the right to withdraw your consent at any time. If you do so, we will stop the processing of your personal data for that specific purpose.

Right to object to processing based on our legitimate interest: You have the right to object to processing of your personal data that is based on our legitimate interest. We will not continue to process the personal data unless we can demonstrate legitimate grounds for the process which overrides your interest and rights or due to legal claims.

Supervisory Authority

In the UK the supervisory authority is The Information Commissioner's Office (ICO) / Information Commission, more information can be found at ico.org.uk.

Contact us

The primary point of contact for all issues arising from this privacy notice, including complaints relating to the processing of your personal data, is our Data Protection Officer. The Data Protection Officer can be contacted by emailing dataprotectionofficer@radius.com.

If you have any questions or concerns regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us.

We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by data protection laws.

Notice of changes

Radius may change or update this People Privacy Notice at any time.

Should we change our approach to data protection, you will be informed of these changes or made aware that we have updated the People Privacy Notice so that you know which information we process and how we use this information.