Privacy Policy

Privacy Standard

    1. 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
    2. 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
    3. 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, signify agreement to the Processing of Personal Data relating to
    4. Data Controller: the person or organisation that determines when, why and how to process Personal 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 all Personal Data used in our business for our own commercial purposes.
    5. Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. A 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. The DPM has responsibility for conducting any required
    6. Data Protection Manager (DPM): the person appointed DPM as data protection manager DPM with responsibility for data protection
    7. Data Subject: a living, identified or identifiable individual about whom we hold Personal Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.
    8. EEA: the 28 countries in the EU, together with Iceland, Liechtenstein and
    9. Explicit Consent: consent which requires a very clear and specific statement (that
    10. is, not just action).
    11. Company: Q9 TRADING LTD
    12. Company Personnel: all employees, workers, contractors, agency workers, consultants, directors, members and others engaged by the Company from time to time, to provide services to the
    13. General Data Protection Regulation (GDPR): the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the
    14. 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 Personal Data includes Sensitive 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 behaviour.
    15. 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 The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.
    16. Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the
    17. Privacy Guidelines: the Company has privacy/GDPR related guidelines provided to assist in interpreting and implementing this Privacy Standard
    18. Privacy Notice (also referred to as Fair Processing Notice): a separate written notice setting out information to be provided to Data Subjects when the Company collects information about
    19. Processing 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
    20. Related Policies: the Company’s policies, operating procedures or processes related to this Privacy Standard and designed to protect Personal
    21. Sensitive Personal Data (also referred to as Special Category 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. The Company also considers all information relating to minors and those incapable of managing their own affairs to be Sensitive Personal Data.
    1. This Privacy Standard sets out how we handle the Personal Data of our landlords, tenants, suppliers, directors, employees and other third
    2. 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 directors, employees, customers, supplier contacts, website users or any other Data
    3. This Privacy Standard applies to all Company 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 disciplinary action.
    4. This Privacy Standard (together with Related Policies and Privacy Guidelines) is an internal document and must not be shared with third parties or regulators without prior authorisation from the
  3. SCOPE
    1. We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business 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.
    2. All directors of the Company are responsible for ensuring all Company Personnel comply with this Privacy Standard and are required to implement appropriate practices, processes, controls and training to ensure such
    3. The DPM is responsible for overseeing this Privacy Standard and, as applicable, developing Related Policies and Privacy Guidelines. That post is held by Saima Rafique.
    4. Please contact the DPM 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 In particular, you must always contact the DPM in the following circumstances:
    5. if you are unsure of the lawful basis on which you are relying to process Personal Data (including the legitimate interests used by the Company;
    6. if you need to rely on Consent and/or need to capture Explicit Consent to process Personal Data;
    7. if you need to draft bespoke Privacy Notices or Fair Processing Notices or to make any amendments to the standard Privacy Notice adopted from time to time by the Company;
    8. if you are unsure about the retention period for the Personal Data being Processed;
    9. if you are unsure about what security or other measures you need to implement to protect Personal Data;
    10. if there has been a Personal Data Breach;
    11. if you are unsure on what basis to transfer Personal Data outside the EEA;
    12. before dealing with any request to exercise rights invoked by a Data Subject;
    13. before engaging in a significant new, or change in, Processing activity which is likely to require a DPIA or plan to use Personal Data for purposes others than what it was collected for;
    14. before undertaking any activities involving Automated Processing including profiling or Automated Decision-Making;
    15. before carrying out direct marketing activities; or
    16. if you need help with any contracts or other areas in relation to sharing Personal Data with third parties (including our vendors).
    1. We adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to be:
    2. Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).
    3. Collected only for specified, explicit and legitimate purposes (Purpose Limitation).
    4. Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Data Minimisation).
    5. Accurate and where necessary kept up to date (Accuracy).
    6. Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).
    7. 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).
    8. Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).
    9. 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).
    10. We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).
      1. Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data
      2. 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
      3. The GDPR allows Processing for specific purposes, some of which are set out below:
        1. the Data Subject has given his or her Consent;
        2. the Processing is necessary for the performance of a contract with the Data Subject;
        3. to meet our legal compliance ;
        4. to protect the Data Subject’s vital interests;
        5. 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 The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices or Fair Processing Notices.
      4. 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
      5. We will generally rely on grounds (a), (b), (c) and (e) above when processing Personal These grounds and the circumstances in which the Company will rely on them are set out in the Privacy Notice.
    2. CONSENT
      1. 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
      2. 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 If Consent is given in a document which deals with other matters, then the Consent must be kept separate from those other matters.
      3. Data Subjects must be easily able to withdraw Consent to Processing at any time and withdrawal must be promptly 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.
      4. 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 Explicit Consent) to Process most types of Sensitive Data. Explicit Consent is obtained by the signature and return of a Privacy
      5. You will need to evidence Consent captured and keep records of all Consents so that the Company can demonstrate compliance with Consent requirements.
      6. Explicit Consent will always be required in respect of data relating to minors or those unable to manage their own affairs. Explicit Consent should be obtained from the parent, lawful guardian or person having parental responsibility in respect of a minor or from the individual having responsibility for the management of the affairs of persons unable to manage their own All such cases should be referred to the DPM.
      7. Explicit consent as at 25 May 2018, has been obtained by the direct e-mailing of a copy of the Privacy Notice and the receipt of the Data Subject’s Consent to the processing of his or her Personal Data in accordance with its
      8. A copy of the Privacy Notice must be placed in the compliance section on the relevant computer A copy of the Data Subject’s Consent (which can be in the form of an e-mail)to the processing of his or her Personal Data in accordance with the Privacy Notice must also be placed in the relevant file and a further copy sent to the DPM.
        1. The GDPR requires Data Controllers to provide detailed, specific information to Data Subjects 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.
        2. 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 DPM, 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
        3. When Personal Data is collected indirectly (for example, from a third party or publically 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
        4. Any Privacy Notices/Fair Processing Notices in a form other than the current version of the standard Privacy Notice must be approved by the DPM prior to
    1. Personal Data must be collected only for specified, explicit and legitimate It must not be further Processed in any manner incompatible with those purposes.
      1. 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
      2. The relevant purposes are set out in the Privacy
    1. Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.
    2. 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.
    3. You may only collect Personal Data that you require for your job duties: do not collect excessive Ensure any Personal Data collected is adequate and relevant for the intended purposes.
    4. You must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or or anonymised.
    1. Personal Data must be accurate and, where necessary, kept up to It must be corrected or deleted without delay when inaccurate.
    2. You must 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
    1. Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is
    2. 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
    3. The Company will maintain file archive and data retention policies and procedures to ensure Personal Data is deleted after a reasonable time, unless a law or professional obligation requires such data to be kept for a minimum You must comply with the Company’s guidelines on archiving of files. Note that early deletion of Personal Data in circumstances where the Company has a legal or professional obligation to maintain its file will result in a breach, by the Company, of non GDPR obligations. Always refer to the Archive Policy before deleting Personal Data.
    4. 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 including, but not limited to, the Archive Policy. This includes requiring third parties to delete such data where
    5. Data Subjects are informed of the period for which data is stored and how that period is determined in the Privacy Notice
      1. Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or unlawful Processing, and against accidental loss, destruction or damage.
      2. We have developed and will continue to 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 where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data.
      3. At the date of this Standard the data protection safeguards and policies developed by the Company (the Data Protection Safeguards) include, but are not limited the Mobile device policy.
      4. You are responsible for protecting the Personal Data we You must comply with the Data Protection Safeguards in order to prevent unlawful or unauthorised Processing of Personal Data and 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.
      5. 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
      6. You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:
        1. Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access
        2. Integrity means that Personal Data is accurate and suitable for the purpose for which it is
        3. Availability means that authorised users are able to access the Personal Data when they need it for authorised
      7. You must comply with and not attempt to circumvent all the relevant provisions of the Data Protection Safeguards, and all of the administrative, physical and technical safeguards we implement and maintain in accordance with the GDPR and relevant standards to protect Personal Data.
      1. The GDPR requires Data Controllers to notify any Personal Data Breach to the applicable regulator and, in certain instances, the Data
      2. 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
      3. If you know or suspect that a Personal Data Breach has occurred or is likely to occur or that there has been a breach of the Data Protection Safeguards, do not attempt to investigate the matter Immediately contact the DPM, or, in the event that the DPM is not immediately available, any Partner of the Company. You should preserve all evidence relating to a potential Personal Data Breach.
    1. 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
    2. You may only transfer Personal Data outside the EEA if one of the following conditions applies:
      1. 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;
      2. 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;
      3. the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or
      4. 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 protect 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.
    3. At the date of this Privacy Standard the European Commission has recognised Andorra, Argentina, Canada (commercial organisations), Faroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland, Uruguay and the US (limited to the Privacy Shield framework) as providing adequate
    4. You must not transfer personal data to or from any country outside the United Kingdom (other than those within the EEA and those listed at paragraph 3 above) without the prior written consent of the DPM.
    1. Data Subjects have rights when it comes to how we handle their Personal These include rights to:
      1. withdraw Consent to Processing at any time;
      2. receive certain information about the Data Controller’s Processing activities;
      3. request access to their Personal Data that we hold;
      4. prevent our use of their Personal Data for direct marketing purposes;
      5. 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;
      6. restrict Processing in specific circumstances;
      7. challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;
      8. request a copy of an agreement under which Personal Data is transferred outside of the EEA;
      9. object to decisions based solely on Automated Processing,  including profiling (ADM);
      10. prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;
      11. be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;
      12. make a complaint to the supervisory authority; and
      13. 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 formet
    2. Requests by Data Subjects to withdraw consent or exercise any of the rights listed above may be made orally or in writing (Data Subject Requests).
    3. You must verify the identity of an individual requesting data under any of the rights listed above .You must take great care not allow third parties to persuade you into disclosing Personal Data without proper
    4. If you receive an oral Data Subject request you must make a written note of the date, time and content of the request as soon as is practicably You must immediately forward any Data Subject request you receive to the DPM.
    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
      1. The Company must have adequate resources and controls in place to ensure and to document GDPR compliance including:
      2. appointing a suitably qualified DPM (where necessary) and an executive accountable for data privacy;
      3. implementing Privacy by Design when Processing Personal Data and completing DPIAs where Processing presents a high risk to rights and freedoms of Data Subjects;
      4. integrating data protection into internal documents including this Privacy Standard, Related Policies, Data Protection Safeguards, Privacy Notices or Fair Processing Notices;
      5. 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
      6. regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement
      1. The GDPR requires us to keep full and accurate records of all our data Processing
      2. You must keep and maintain accurate corporate records reflecting our Processing including records of Data Subjects’ Consents and procedures for obtaining Consents [in accordance with the procedures set out in this Privacy Standard
      3. These records should include, at a minimum, the name and contact details of the Data Controller and the DPM, 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
      1. 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
      2. You must undergo all mandatory data privacy related training. Mandatory training includes but is not limited to reading this Privacy
      3. 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 are in place to ensure proper use and protection of Personal If you believe that additional systems, processes or resources are necessary in order for you to comply with this Privacy Standard you should inform the DPM.
      1. We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures (such as the Data Protection Safeguards) in an effective manner, to ensure compliance with data privacy principles.
      2. We 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:
        1. the cost of implementation;
        2. the nature, scope, context and purposes of Processing; and
        3. the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the Processing.
      3. Data controllers must also conduct DPIAs in respect to high risk Processing including the processing of Sensitive Personal
      4. You should ask the DPM to conduct a DPIA when implementing major system or business change programs involving the Processing of Personal Data including:
        1. use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes);
        2. Automated Processing including profiling and ADM;
        3. large scale Processing of Sensitive Data; and
        4. large scale, systematic monitoring of a publicly accessible are.
      5. A DPIA must include:
        1. a description of the Processing, its purposes and the Data Controller’s legitimate interests if appropriate;
        2. an assessment of the necessity and proportionality of the Processing in relation to its purpose;
        3. an assessment of the risk to individuals; and
        4. the risk mitigation measures in place and demonstration of compliance.
      1. Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless:
        1. a Data Subject has Explicitly Consented;
        2. the Processing is authorised by law; or
        3. the Processing is necessary for the performance of or entering into a contract.
      2. If certain types of Sensitive Data are being processed, then grounds or 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 prevention.
      3. 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 Further, suitable measures must be put in place to safeguard the Data Subject’s rights and freedoms and legitimate interests.
      4. 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 decision.
      5. A DPIA must be carried out before any Automated Processing (including profiling) or ADM activities are undertaken.
      6. You must not carry out any Data Processing activity that involves profiling or ADM, without the prior written approval of the DPM.
      1. Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in
      2. You may only share the Personal Data we hold with another employee, agent contractor or representative of the Company if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer
      3. We may only share the Personal Data we hold with third parties, such as our service providers if:
        1. they have a need to know the information for the purposes of providing the contracted services;
        2. 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;
        3. the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
        4. the transfer complies with any applicable cross border transfer restrictions; and
        5. a fully executed written contract that contains GDPR approved third party clauses has been obtained.
      4. You must not share Personal Data with third parties unless the third party has been approved by the DPM.
    1. 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. We last revised this Privacy Standard on 24 May
    2. This Privacy Standard does not override any applicable national data privacy laws and regulations in countries where the Company
    1. I acknowledge that I have received and read a copy of the Privacy Standard and understand that I am responsible for knowing and abiding by its terms. I understand that the information in this Privacy Standard is intended to help the Company, it’s directors employees and contractors to work together effectively on assigned job responsibilities and assist in the use and protection of Personal Data.
    2. I understand that this Privacy Standard does not set terms or conditions of employment or form part of an employment contract.