Quantum Engineering Developments Limited

Privacy Policy



Automated Decision-Making (ADM): when a decision is made which is based

solely on Automated Processing (including profiling) which produces legal effects or

significantly affects an individual. The GDPR prohibits Automated Decision-Making

(unless certain conditions are met) but not Automated Processing.

Automated Processing: any form of automated processing of Personal Data

consisting of the use of Personal Data to evaluate certain personal aspects relating

to an individual, in particular to analyse or predict aspects concerning that

individual’s performance at work, economic situation, health, personal preferences,

interests, reliability, behaviour, location or movements. Profiling is an example of

Automated Processing.

Company name: Quantum Engineering Developments Limited

Company Personnel: all employees, workers, contractors, agency workers,

consultants, directors, members and others.

Consent: agreement which must be freely given, specific, informed and be an

unambiguous indication of the Data Subject’s wishes by which they, by a statement

or by a clear positive action, signifies agreement to the Processing of Personal Data

relating to them.

Data Controller: the person or organisation that determines when, why and how

to process Personal Data. It is responsible for establishing practices and policies in

line with the GDPR. We are the Data Controller of all Personal Data relating to our

Company Personnel and Personal Data used in our business for our own commercial


Data Subject: a living, identified or identifiable individual about whom we hold

Personal Data. Data Subjects may be nationals or residents of any country and may

have legal rights regarding their Personal Data.

Data Privacy Impact Assessment (DPIA): tools and assessments used to

identify and reduce risks of a data processing activity. DPIA can be carried out as

part of Privacy by Design and should be conducted for all major system or business

change programs involving the Processing of Personal Data.

Company Registration Number: 2947971Data Protection Officer (DPO): the person required to be appointed in specific

circumstances under the GDPR. Where a mandatory DPO has not been appointed,

this term means a data protection manager or other voluntary appointment of a DPO

or refers to the Company data privacy team with responsibility for data protection


EEA: the 28 countries in the EU, and Iceland, Liechtenstein and Norway.

Explicit Consent: consent which requires a very clear and specific statement (that

is, not just action).

General Data Protection Regulation (GDPR): the General Data Protection

Regulation ((EU) 2016/679 ). Personal Data is subject to the legal safeguards

specified in the GDPR.

Personal Data: any information identifying a Data Subject or information relating

to a Data Subject that we can identify (directly or indirectly) from that data alone or

in combination with other identifiers we possess or can reasonably access. Personal

Data includes Sensitive Personal Data and Pseudonymised Personal Data but

excludes anonymous data or data that has had the identity of an individual

permanently removed. Personal data can be factual (for example, a name, email

address, location or date of birth) or an opinion about that person’s actions or


Personal Data Breach: any act or omission that compromises the security,

confidentiality, integrity or availability of Personal Data or the physical, technical,

administrative or organisational safeguards that we or our third-party service

providers put in place to protect it. The loss, or unauthorised access, disclosure or

acquisition, of Personal Data is a Personal Data Breach.

Privacy by Design: implementing appropriate technical and organisational

measures in an effective manner to ensure compliance with the GDPR.

Privacy Guidelines: the Company privacy/GDPR related guidelines provided to

assist in interpreting and implementing this Privacy Standard and Related Policies are

available from Peter Hogsden.

Privacy Notices (also referred to as Fair Processing Notices) or Privacy

Policies: separate notices setting out information that may be provided to Data

Subjects when the Company collects information about them. These notices may

take the form of general privacy statements applicable to a specific group of

individuals (for example, employee privacy notices or the website privacy policy) or

they may be stand-alone, one-time privacy statements covering Processing related

to a specific purpose.

Company Registration Number: 2947971Processing or Process: any activity that involves the use of Personal Data. It

includes obtaining, recording or holding the data, or carrying out any operation or

set of operations on the data including organising, amending, retrieving, using,

disclosing, erasing or destroying it. Processing also includes transmitting or

transferring Personal Data to third parties.

Pseudonymisation or Pseudonymised: replacing information that directly or

indirectly identifies an individual with one or more artificial identifiers or pseudonyms

so that the person, to whom the data relates, cannot be identified without the use of

additional information which is meant to be kept separately and secure.

Related Policies: the Company’s policies, operating procedures or processes

related to this Privacy Standard and designed to protect Personal Data are available

from Peter Hogsden.

Sensitive Personal Data: information revealing racial or ethnic origin, political

opinions, religious or similar beliefs, trade union membership, physical or mental

health conditions, sexual life, sexual orientation, biometric or genetic data, and

Personal Data relating to criminal offences and convictions.


This Privacy Standard sets out how Quantum Engineering Developments Limited (”

we”, “our”, “us”, “the Company”) handle the Personal Data of our customers,

suppliers, employees, workers and other third parties.

This Privacy Standard applies to all Personal Data we Process regardless of the

media on which that data is stored or whether it relates to past or present

employees, workers, customers, clients or supplier contacts, shareholders, website

users or any other Data Subject.

This Privacy Standard applies to all Company Personnel (” you”, “your”). You must

read, understand and comply with this Privacy Standard when Processing Personal

Data on our behalf and attend training on its requirements. This Privacy Standard

sets out what we expect from you in order for the Company to comply with

applicable law. Your compliance with this Privacy Standard is mandatory. Related

Policies and Privacy Guidelines are available to help you interpret and act in

accordance with this Privacy Standard. You must also comply with all such Related

Policies and Privacy Guidelines. Any breach of this Privacy Standard may result in

Company Registration Number: 2947971disciplinary action.

This Privacy Standard (together with Related Policies and Privacy Guidelines) is an

internal document and cannot be shared with third parties, clients or regulators

without prior authorisation from the DPO.


We recognise that the correct and lawful treatment of Personal Data will maintain

confidence in the organisation and will provide for successful business operations.

Protecting the confidentiality and integrity of Personal Data is a critical responsibility

that we take seriously at all times. The Company is exposed to potential fines of up

to EUR20 million (approximately £18 million) or 4% of total worldwide annual

turnover, whichever is higher and depending on the breach, for failure to comply

with the provisions of the GDPR.

The Companies owners are responsible for ensuring all Company Personnel comply

with this Privacy Standard and need to implement appropriate practices, processes,

controls and training to ensure such compliance.

The DPO is responsible for overseeing this Privacy Standard and, as applicable,

developing Related Policies and Privacy Guidelines. Peter Hogsden, is designated


Please contact the DPO with any questions about the operation of this Privacy

Standard or the GDPR or if you have any concerns that this Privacy Standard is not

being or has not been followed. In particular, you must always contact the DPO in

the following circumstances:

(a) if you are unsure of the lawful basis which you are relying on to process

Personal Data (including the legitimate interests used by the Company) (see Section

[5.1] below);

(b) if you need to rely on Consent and/or need to capture Explicit Consent (see

Section [5.2] below);

(c) if you need to draft Privacy Notices or Fair Processing Notices (see Section [5.3]


(d) if you are unsure about the retention period for the Personal Data being

Processed (see Section [9] below);

Company Registration Number: 2947971(e) if you are unsure about what security or other measures you need to implement

to protect Personal Data (see Section [10.1] below);

(f) if there has been a Personal Data Breach (Section [10.2] below);

(g) if you are unsure on what basis to transfer Personal Data outside the EEA (see

Section [11] below);

(h) if you need any assistance dealing with any rights invoked by a Data Subject

(see Section [12 ] );

(i) whenever you are engaging in a significant new, or change in, Processing

activity which is likely to require a DPIA (see Section [13.4 ] below) or plan to use

Personal Data for purposes others than what it was collected for;

(j) If you plan to undertake any activities involving Automated Processing including

profiling or Automated Decision-Making (see Section [13.5 ] below);

(k) If you need help complying with applicable law when carrying out direct

marketing activities (see Section [13.6] below); or

(l) if you need help with any contracts or other areas in relation to sharing Personal

Data with third parties (including our vendors) (see Section [13.7 ] below).


We adhere to the principles relating to Processing of Personal Data set out in the

GDPR which require Personal Data to be:

a) Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness

and Transparency).

b) Collected only for specified, explicit and legitimate purposes (Purpose


c) Adequate, relevant and limited to what is necessary in relation to the

purposes for which it is Processed (Data Minimisation).

d) Accurate and where necessary kept up to date (Accuracy).

e) Not kept in a form which permits identification of Data Subjects for longer

Company Registration Number: 2947971than is necessary for the purposes for which the data is Processed (Storage


f) Processed in a manner that ensures its security using appropriate technical

and organisational measures to protect against unauthorised or unlawful

Processing and against accidental loss, destruction or damage (Security,

Integrity and Confidentiality).

g) Not transferred to another country without appropriate safeguards being in

place (Transfer Limitation).

h) Made available to Data Subjects and Data Subjects allowed to exercise certain

rights in relation to their Personal Data (Data Subject’s Rights and Requests).

We are responsible for and must be able to demonstrate compliance with the data

protection principles listed above (Accountability).



Personal data must be Processed lawfully, fairly and in a transparent manner in

relation to the Data Subject.

You may only collect, Process and share Personal Data fairly and lawfully and for

specified purposes. The GDPR restricts our actions regarding Personal Data to

specified lawful purposes. These restrictions are not intended to prevent Processing

but ensure that we Process Personal Data fairly and without adversely affecting the

Data Subject.

The GDPR allows Processing for specific purposes, some of which are set out below:

a) the Data Subject has given his or her Consent;

b) the Processing is necessary for the performance of a contract with the Data


c) to meet our legal compliance obligations.;

d) to protect the Data Subject’s vital interests;

Company Registration Number: 2947971e) to pursue our legitimate interests for purposes where they are not overridden

because the Processing prejudices the interests or fundamental rights and

freedoms of Data Subjects. The purposes for which we process Personal Data

for legitimate interests need to be set out in applicable Privacy Notices or Fair

Processing Notices; or

You must identify and document the legal ground being relied on for each

Processing activity [in accordance with the Company’s guidelines on Lawful Basis for

Processing Personal Data].


A Data Controller must only process Personal Data on the basis of one or more of

the lawful bases set out in the GDPR, which include Consent.

A Data Subject consents to Processing of their Personal Data if they indicate

agreement clearly either by a statement or positive action to the Processing. Consent

requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be

sufficient. If Consent is given in a document which deals with other matters, then

the Consent must be kept separate from those other matters.

Data Subjects must be easily able to withdraw Consent to Processing at any time

and withdrawal must be promptly honoured. Consent may need to be refreshed if

you intend to Process Personal Data for a different and incompatible purpose which

was not disclosed when the Data Subject first consented.

Unless we can rely on another legal basis of Processing, Explicit Consent is usually

required for Processing Sensitive Personal Data, for Automated Decision-Making and

for cross border data transfers. Usually we will be relying on another legal basis (and

not require Explicit Consent) to Process most types of Sensitive Data. Where Explicit

Consent is required, you must issue a Fair Processing Notice to the Data Subject to

capture Explicit Consent.

You will need to evidence Consent captured and keep records of all Consents so that

the Company can demonstrate compliance with Consent requirements.


The GDPR requires Data Controllers to provide detailed, specific information to Data

Company Registration Number: 2947971Subjects depending on whether the information was collected directly from Data

Subjects or from elsewhere. Such information must be provided through appropriate

Privacy Notices or Fair Processing Notices which must be concise, transparent,

intelligible, easily accessible, and in clear and plain language so that a Data Subject

can easily understand them.

Whenever we collect Personal Data directly from Data Subjects, including for human

resources or employment purposes, we must provide the Data Subject with all the

information required by the GDPR including the identity of the Data Controller and

DPO, how and why we will use, Process, disclose, protect and retain that Personal

Data through a Fair Processing Notice which must be presented when the Data

Subject first provides the Personal Data.

When Personal Data is collected indirectly (for example, from a third party or

publicly available source), you must provide the Data Subject with all the information

required by the GDPR as soon as possible after collecting/receiving the data. You

must also check that the Personal Data was collected by the third party in

accordance with the GDPR and on a basis which contemplates our proposed

Processing of that Personal Data.


Personal Data must be collected only for specified, explicit and legitimate purposes.

It must not be further Processed in any manner incompatible with those purposes.

You cannot use Personal Data for new, different or incompatible purposes from that

disclosed when it was first obtained unless you have informed the Data Subject of

the new purposes and they have Consented where necessary.


Personal Data must be adequate, relevant and limited to what is necessary in

relation to the purposes for which it is Processed.

You may only Process Personal Data when performing your job duties requires it.

You cannot Process Personal Data for any reason unrelated to your job duties.

You may only collect Personal Data that you require for your job duties: do not

collect excessive data. Ensure any Personal Data collected is adequate and relevant

Company Registration Number: 2947971for the intended purposes.

You must ensure that when Personal Data is no longer needed for specified

purposes, it is deleted or anonymised in accordance with the Company’s data

retention guidelines.


Personal Data must be accurate and, where necessary, kept up to date. It must be

corrected or deleted without delay when inaccurate.

You will ensure that the Personal Data we use and hold is accurate, complete, kept

up to date and relevant to the purpose for which we collected it. You must check the

accuracy of any Personal Data at the point of collection and at regular intervals

afterwards. You must take all reasonable steps to destroy or amend inaccurate or

out-of-date Personal Data.


Personal Data must not be kept in an identifiable form for longer than is necessary

for the purposes for which the data is processed.

You must not keep Personal Data in a form which permits the identification of the

Data Subject for longer than needed for the legitimate business purpose or purposes

for which we originally collected it including for the purpose of satisfying any legal,

accounting or reporting requirements.

The Company will maintain retention policies and procedures to ensure Personal

Data is deleted after a reasonable time for the purposes for which it was being held

unless a law requires such data to be kept for a minimum time. You must comply

with the Company’s guidelines on Data Retention.

You will take all reasonable steps to destroy or erase from our systems all Personal

Data that we no longer require in accordance with all the Company’s applicable

records retention schedules and policies. This includes requiring third parties to

delete such data where applicable.

You will ensure Data Subjects are informed of the period for which data is stored

and how that period is determined in any applicable Privacy Notice or Fair Processing

Company Registration Number: 2947971Notice.



Personal Data must be secured by appropriate technical and organisational

measures against unauthorised or unlawful Processing, and against accidental loss,

destruction or damage.

We will develop, implement and maintain safeguards appropriate to our size, scope

and business, our available resources, the amount of Personal Data that we own or

maintain on behalf of others and identified risks (including use of encryption and

Pseudonymisation where applicable). We will regularly evaluate and test the

effectiveness of those safeguards to ensure security of our Processing of Personal

Data. You are responsible for protecting the Personal Data we hold. You must

implement reasonable and appropriate security measures against unlawful or

unauthorised Processing of Personal Data and against the accidental loss of, or

damage to, Personal Data. You must exercise particular care in protecting Sensitive

Personal Data from loss and unauthorised access, use or disclosure.

You must follow all procedures and technologies we put in place to maintain the

security of all Personal Data from the point of collection to the point of destruction.

You may only transfer Personal Data to third-party service providers who agree to

comply with the required policies and procedures and who agree to put adequate

measures in place, as requested.

You must maintain data security by protecting the confidentiality, integrity and

availability of the Personal Data, defined as follows:

a) Confidentiality means that only people who have a need to know and are

authorised to use the Personal Data can access it.

b) Integrity means that Personal Data is accurate and suitable for the purpose

for which it is processed.

c) Availability means that authorised users are able to access the Personal Data

when they need it for authorised purposes.

Company Registration Number: 294797110.2 REPORTING A PERSONAL DATA BREACH

The GDPR requires Data Controllers to notify any Personal Data Breach to the

applicable regulator and, in certain instances, the Data Subject.

We have put in place procedures to deal with any suspected Personal Data Breach

and will notify Data Subjects or any applicable regulator where we are legally

required to do so.

If you know or suspect that a Personal Data Breach has occurred, do not attempt to

investigate the matter yourself. Immediately contact the person or team designated

as the key point of contact for Personal Data Breaches. You should preserve all

evidence relating to the potential Personal Data Breach.


The GDPR restricts data transfers to countries outside the EEA in order to ensure

that the level of data protection afforded to individuals by the GDPR is not

undermined. You transfer Personal Data originating in one country across borders

when you transmit, send, view or access that data in or to a different country.

You may only transfer Personal Data outside the EEA if one of the following

conditions applies:

a) the European Commission has issued a decision confirming that the country

to which we transfer the Personal Data ensures an adequate level of

protection for the Data Subjects’ rights and freedoms;

b) appropriate safeguards are in place such as binding corporate rules (BCR),

standard contractual clauses approved by the European Commission, an

approved code of conduct or a certification mechanism, a copy of which can

be obtained from the DPO;

c) the Data Subject has provided Explicit Consent to the proposed transfer after

being informed of any potential risks; or

d) the transfer is necessary for one of the other reasons set out in the GDPR

including the performance of a contract between us and the Data Subject,

reasons of public interest, to establish, exercise or defend legal claims or to

Company Registration Number: 2947971protect the vital interests of the Data Subject where the Data Subject is

physically or legally incapable of giving Consent and, in some limited cases,

for our legitimate interest.


Data Subjects have rights when it comes to how we handle their Personal Data.

These include rights to:

a) withdraw Consent to Processing at any time;

b) receive certain information about the Data Controller’s Processing activities;

c) request access to their Personal Data that we hold;

d) prevent our use of their Personal Data for direct marketing purposes;

e) ask us to erase Personal Data if it is no longer necessary in relation to the

purposes for which it was collected or Processed or to rectify inaccurate data

or to complete incomplete data;

f) restrict Processing in specific circumstances;

g) challenge Processing which has been justified on the basis of our legitimate

interests or in the public interest;

h) request a copy of an agreement under which Personal Data is transferred

outside of the EEA;

i) object to decisions based solely on Automated Processing, including profiling


j) prevent Processing that is likely to cause damage or distress to the Data

Subject or anyone else;

k) be notified of a Personal Data Breach which is likely to result in high risk to

their rights and freedoms;

l) make a complaint to the supervisory authority; and

Company Registration Number: 2947971m) in limited circumstances, receive or ask for their Personal Data to be

transferred to a third party in a structured, commonly used and machine-

readable format.

You must verify the identity of an individual requesting data under any of the rights

listed above (do not allow third parties to persuade you into disclosing Personal Data

without proper authorisation).

You must immediately forward any Data Subject request you receive to Peter



13.1 The Data Controller must implement appropriate technical and organisational

measures in an effective manner, to ensure compliance with data protection

principles. The Data Controller is responsible for, and must be able to demonstrate,

compliance with the data protection principles.

The Company must have adequate resources and controls in place to ensure and to

document GDPR compliance including:

a) appointing a suitably qualified DPO (where necessary) and an executive

accountable for data privacy;

b) implementing Privacy by Design when Processing Personal Data and

completing DPIAs where Processing presents a high risk to rights and

freedoms of Data Subjects;

c) integrating data protection into internal documents including this Privacy

Standard, Related Policies, Privacy Guidelines, Privacy Notices or Fair

Processing Notices;

d) regularly training Company Personnel on the GDPR, this Privacy Standard,

Related Policies and Privacy Guidelines and data protection matters including,

for example, Data Subject’s rights, Consent, legal basis, DPIA and Personal

Data Breaches. The Company must maintain a record of training attendance

by Company Personnel; and

e) regularly testing the privacy measures implemented and conducting periodic

Company Registration Number: 2947971reviews and audits to assess compliance, including using results of testing to

demonstrate compliance improvement effort.


The GDPR requires us to keep full and accurate records of all our data Processing


You must keep and maintain accurate corporate records reflecting our Processing

including records of Data Subjects’ Consents and procedures for obtaining Consents.

These records should include, at a minimum, the name and contact details of the

Data Controller and the DPO, clear descriptions of the Personal Data types, Data

Subject types, Processing activities, Processing purposes, third-party recipients of

the Personal Data, Personal Data storage locations, Personal Data transfers, the

Personal Data’s retention period and a description of the security measures in place.

In order to create such records, data maps should be created which should include

the detail set out above together with appropriate data flows.


We are required to ensure all Company Personnel have undergone adequate training

to enable them to comply with data privacy laws. We must also regularly test our

systems and processes to assess compliance.

You must regularly review all the systems and processes under your control to

ensure they comply with this Privacy Standard and check that adequate governance

controls and resources are in place to ensure proper use and protection of Personal




We are required to implement Privacy by Design measures when Processing

Personal Data by implementing appropriate technical and organisational measures

(like Pseudonymisation) in an effective manner, to ensure compliance with data

privacy principles.

Company Registration Number: 2947971You must assess what Privacy by Design measures can be implemented on all

programs/systems/processes that Process Personal Data by taking into account

the following:

a) the state of the art;

b) the cost of implementation;

c) the nature, scope, context and purposes of Processing; and

d) the risks of varying likelihood and severity for rights and freedoms of Data

Subjects posed by the Processing.

Data controllers must also conduct DPIAs in respect to high risk Processing.

You should conduct a DPIA (and discuss your findings with the DPO) when

implementing major system or business change programs involving the Processing of

Personal Data including:

a) use of new technologies (programs, systems or processes), or changing

technologies (programs, systems or processes);

b) Automated Processing including profiling and ADM;

c) large scale Processing of Sensitive Data; and

d) large scale, systematic monitoring of a publicly accessible area.

A DPIA must include:

a) a description of the Processing, its purposes and the Data Controller’s

legitimate interests if appropriate;

b) an assessment of the necessity and proportionality of the Processing in

relation to its purpose;

c) an assessment of the risk to individuals; and

Company Registration Number: 2947971 Company Registration Number: 2947971d) the risk mitigation measures in place and demonstration of compliance.



Generally, ADM is prohibited when a decision has a legal or similar significant effect

on an individual unless:

a) a Data Subject has Explicitly Consented;

b) the Processing is authorised by law; or

c) the Processing is necessary for the performance of or entering into a contract.

If certain types of Sensitive Data are being processed, then grounds (b) or (c) will

not be allowed but such Sensitive Data can be Processed where it is necessary

(unless less intrusive means can be used) for substantial public interest like fraud


If a decision is to be based solely on Automated Processing (including profiling),

then Data Subjects must be informed when you first communicate with them of their

right to object. This right must be explicitly brought to their attention and presented

clearly and separately from other information. Further, suitable measures must be

put in place to safeguard the Data Subject’s rights and freedoms and legitimate


We must also inform the Data Subject of the logic involved in the decision making or

profiling, the significance and envisaged consequences and give the Data Subject

the right to request human intervention, express their point of view or challenge the


A DPIA must be carried out before any Automated Processing (including profiling) or

ADM activities are undertaken.


We are subject to certain rules and privacy laws when marketing to our customers.

Company Registration Number: 2947971For example, a Data Subject’s prior consent is required for electronic direct

marketing (for example, by email, text or automated calls). The limited exception for

existing customers known as “soft opt in” allows organisations to send marketing

texts or emails if they have obtained contact details in the course of a sale to that

person, they are marketing similar products or services, and they gave the person an

opportunity to opt out of marketing when first collecting the details and in every

subsequent message.

The right to object to direct marketing must be explicitly offered to the Data Subject

in an intelligible manner so that it is clearly distinguishable from other information.

A Data Subject’s objection to direct marketing must be promptly honoured. If a

customer opts out at any time, their details should be suppressed as soon as

possible. Suppression involves retaining just enough information to ensure that

marketing preferences are respected in the future.


Generally, we are not allowed to share Personal Data with third parties unless

certain safeguards and contractual arrangements have been put in place.

You may only share the Personal Data we hold with another employee, agent or

representative of our group (which includes our subsidiaries and our ultimate holding

company along with its subsidiaries) if the recipient has a job-related need to know

the information and the transfer complies with any applicable cross-border transfer


You may only share the Personal Data we hold with third parties, such as our service

providers if:

a. they have a need to know the information for the purposes of providing the

contracted services;

b. sharing the Personal Data complies with the Privacy Notice provided to the

Data Subject and, if required, the Data Subject’s Consent has been obtained;

c. the third party has agreed to comply with the required data security

standards, policies and procedures and put adequate security measures in


Company Registration Number: 2947971d. the transfer complies with any applicable cross border transfer restrictions;


e. a fully executed written contract that contains GDPR approved third party

clauses has been obtained.


We reserve the right to change this Privacy Standard at any time without notice to

you so please check back regularly to obtain the latest copy of this Privacy Standard.

This Privacy Standard does not override any applicable national data privacy laws

and regulations in countries where the Company operates.

If you require any further information please contact us on +44 (0) 1527 577 888