MACE Connected Workplace App Privacy Notice

Last Updated: June 2022

1. About this privacy notice

This privacy notice informs you about how we process your personal data when you use the [Mace Connected Workplace] app. This privacy notice supplements our general employee privacy notice which can be found: Infomace | Mace Policy Zone | (macegroup.com). Please read this privacy notice in conjunction with our general employee privacy notice.

The app provides the services described at paragraph 4. The personal data that we process will depend on the services that you use within the app.

It is up to you to decide whether you would like to make use of the app and the services. To use the app, we require certain personal data. If you choose not to provide the personal data that is required to use the app, we will not be able to provide the services and you will not be able to use the app. The provision of certain personal data may be optional. You will be able to use our app and services even if you do not provide such optional data to us.

2. Who is the data controller?

The Mace group is made up of different legal entities, details of which can be found on the Mace intranet (https://info.macegroup.com/centralsupport/finance/corporate.aspx). When we refer to ‘Mace’, ‘we’, us’, or ‘our’, we are referring to the relevant company in the Mace group responsible for processing your personal data.  A reference to ‘you’ or ‘your’ is to you as an individual.

In most circumstances, the Mace group company that employs you will be the data controller in respect of the processing of personal data referred to within this privacy notice. For the majority of employees in the UK, this will be Mace Limited of 155 Moorgate, London EX2M 6XB.

We have appointed a European Representative. Our European Representative is:

Mace Group I.C.S Limited

5th Floor, Beaux Lane House

Mercer Street Lower

Dublin 2

Ireland

Email: gdpr@macegroup.com

3. What personal data is collected?

Depending on which aspect of the services that you use, Mace may collect and use the following personal data about you:

• Contact and registration details: name/surname, job title, Mace email address, Mace telephone number(s), username, passwords, identification credentials for the app, Mace profile photo, the Mace floor, office and country in which you work.
• Booking information: desk and location of desk, meeting room, meeting name, number of participants, name of organiser and attendees.
• Single sign on: Mace Connected Workplace will use the single sign on to enter the app and therefore your Mace email address.
• General requests: requests, feedback or questions to local operational teams raised by you via the app.
• Industry-standard log data: device type, browser, and operating system you are using and your IP address at the time of the creation of your user account.
• Technical information: type of mobile device you use, software version, details of your browser, unique device identifiers, mobile network information, user consent for connected apps and devices, user preferences, your mobile operating system and your time zone setting.
• Analytics information relating to your use of the services or the app and device information: traffic data, app activity, location data and other communication data, and the resources that you access.
• Other information you provide to us in connection with your use of the services or the app such as preferences and feedback, and technical and bug fixing information.
• Any further information which you provide to us when you interact with us.

Precise location data (if you have consented).

Certain app services require your precise location data. If you don’t consent to provide your location data, those services will not be available to you. Location co-ordinates when you are outside a Mace site or office are not collected or stored. Location co-ordinates when you are inside a Mace site or office may be stored but only temporarily and only your last location is held (i.e. the previous co-ordinates are overwritten). The app never records co-ordinates for washrooms, multi faith rooms, showers, nursing rooms or any similarly sensitive locations. The information the app collects is used to detect what building you are working from to provide location-based features (such as “Find a Colleague”) and to know where you are in the building for features such as location-based notifications.

4. How is your personal data collected?

We will collect information that you input directly into the app, for example, by signing in or entering information directly into the app.

We will also collect information automatically via the app. This information may include your precise location when the app is either open, minimised in the background or when fully closed but only if you have provided separate consent for the app to collect this information.

5. What purposes will we use your personal data for?

Mace will use your personal data to provide the services available on the app including for the following purposes:

• to authenticate you to log in to the app in our legitimate interests to ensure the security of the app;
• to enable you to book desks and space in Mace sites and offices in our legitimate interests to efficiently manage space in our sites and offices;
• where you identify issues in Mace sites and offices, to enable you to raise a service ticket to identify those issues to the Mace facilities maintenance team in our legitimate interests of keeping Mace sites and offices in good working order;
• to enable you to use the app as a security pass to allow access to Mace sites and offices in our legitimate interests to ensure efficient access to our sites and offices;
• with your consent, we will use your location to:
  • direct you to certain areas within Mace sites and offices;
  • provide you with information about facilities and services available to you in that location;
  • provide you with real time information about room bookings and availability; and
  • enable colleagues to find you using your precise location in a Mace site or office via the ‘Find a colleague’ feature;
• to enable you to access catering services to view menus and order catering
• to enable Mace operation and building services to analyse the booking and feedback data in order to provide the best working experience and workplace

6. Who will your personal data be shared with?

We will share your personal data in connection with the purposes described above with the following third parties:

• other companies in the Mace Group;
• our third party app provider, Spica Technologies Limited;
• third parties who support the provision of the app and services;

7. International transfers

The Mace group will process your personal data locally in the country in which you are located at the time that the app is used. You may be able to access different Mace location and site to allow you to wok where you need.

We may also transfer your personal data outside the UK and EEA to other third parties in the provision in the app. We will only do so if adequate protection measures are in place in compliance with the applicable data protection laws. We use the following protection measures:

• transferring to countries that have been deemed to provide an adequate level of protection;
• using approved model contractual clauses; or
• transferring where an exception applies under the applicable data protection law.

8. How is your data stored and kept secure?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from the Data Protection Compliance Manager.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

9. How long will we keep your personal data for?

We only store your information for as long as is required for the purpose it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

10. What are your rights?

You have the following rights. You can exercise these rights at any time by contacting the Data Protection Compliance Manager. You can make a subject access request verbally or in writing. In order to deal with your request effectively, it would be helpful if you could contact the Data Protection Compliance Manager in the first instance.

The Data Protection Compliance Manager may be contacted in the following ways:

• By post: Data Protection Compliance Manager (Legal Department), Mace Ltd, 155 Moorgate, London EC2M 6XB
• By email: gdpr@macegroup.com
• By telephone: +44 (0)20 3522 4922

You have the right:

• to ask us not to process your personal data for marketing purposes;
• to ask us not to process your personal data where it is processed on the basis of legitimate interests provided that there are no compelling reasons for that processing;
• where processing of your personal data is based on consent, to withdraw that consent at any time;
• to request from us access to personal information held about you;
• to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;

• to ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there are no overriding legitimate ground for processing, the data is unlawfully processed, the data needs to be erased to comply with a legal obligation;
• to ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected or you exercise your right to object (pending verification of whether there are legitimate grounds for processing); or
• to ask for data portability if the processing is carried out by automated means and the legal basis for processing is consent or contract.

Should you have any issues, concerns or problems in relation to your data, or wish to notify us of data which is inaccurate, please let us know by contacting us using the contact details above. In the event that you are not satisfied with our processing of your Personal Data, you have the right to lodge a complaint with the relevant supervisory authority at any time. The relevant supervisory authority in the UK is the Information Commissioner’s Office (ICO).  The ICO’s contact details are available here: https://ico.org.uk/concerns/.

11. Changes to our fair processing notice

This privacy notice may be updated from time to time.

12. Contact us

Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to your line manager in the first instance. If you still have queries or concerns or if you are not comfortable discussing with your line manager then you can contact the Data Protection Compliance Manager at gdpr@macegroup.com or 020 3522 4922.