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GDPR Policy

The EU General Data Protection Regulation (“GDPR”) was replaced for UK business by the UK General Data Protection Regulation (UK GDPR), tailored by the Data Protection Act 2018.

It is supported by the Guide to the UK General Data Protection Regulation (UK GDPR) that details each of the data protection principles, rights and obligations.  It summarises the key points to be understood, answers frequently asked questions, and contains practical checklists to help you comply.


Codex Integrity Limited (‘Codex’ ‘we’, ‘us’ or ‘our’) are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognised our obligations in updating and expanding this program to meet the demands of the UK GDPR and the UK’s Data Protection Bill.

Codex are dedicated to safeguarding the personal information under our remit and developed a data protection regime that is effective, fit for purpose and demonstrated an understanding of, and appreciation for the new Regulation. Our achieved objectives for UK GDPR compliance are summarised in this statement and included the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

Codex act as data controllers of our own employee data and business CRM data regarding contacts and clients and as data processors for the services that we provide.


We already have a consistent level of data protection and security for employees, customers, suppliers and 3rd parties across our organisation, and have actively taken the necessary steps for GDPR compliance. These steps include, but are not limited to: –

Information Audit – carried out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.

Policies & Procedures – the revision of and implementation of new data protection policies and procedures to meet the requirements and standards of the UK GDPR and any relevant data protection laws, including: –

  • Data Protection Policy – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the UK GDPR.
  • Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.
  • Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow.
  • Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate. Subject Access Requests can be made by contacting

Legal Basis for Processing – we have reviewed all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to.

Privacy Notice/Policy – we have revised our Privacy Notice(s) to comply with the UK GDPR, ensuring that all individuals whose personal information we process as a data controller have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.

Obtaining Consent – we have revised our mechanisms where we obtain consent for personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information.

Direct Marketing – we have revised the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.

Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the UK GDPR requirements.

Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have in place relevant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our UK GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organisational measures in place and compliance with the GDPR.

Special Categories Data – where we obtain and process any special category information, we do so in complete compliance and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate basis or conditions. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.


Codex take the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures.


Codex have designated the HSEQ Advisor as our Appointed Person with regard to the new data protection regulation. The Appointed Person along with our HR function and induction process are responsible for promoting awareness of the UK GDPR across the organisation, as well as ensuring that policies and procedures are adhered to and reviewed on a regular basis to ensure ongoing compliance.

Codex understand that continuous employee awareness and understanding is vital to the continued compliance of the UK GDPR and have involved our employees in our preparation plans. We have implemented an employee training program which is provided to all employees and forms part of our induction and annual training program.

If you have any questions about our preparation for the UK GDPR, please contact us at