This Privacy Policy sets out how QUAD CODE uses the personal information relating to its prospective, current and former employees, temporary and contract staff and third party contractors ("you" and "your ''). QUAD CODE is active across the world. We have offices and entities located in Cyprus, Gibraltar, Australia, Bahamas, the United Arab Emirates and the United Kingdom (together with their respective affiliated QUAD CODE Entities) so when we mention “QUAD CODE”, “Company”, “we” or “us” in this Privacy Policy we are referring to the relevant QUAD CODE Entity responsible for collecting and/or processing your data. In each case, your personal data will be controlled by the QUAD CODE Entity which you have given instructions to, or with which you are otherwise dealing with or receiving communications from or the QUAD CODE Entity which provides services to a third party which you are associated with, for example a company of which you are a director or shareholder.

This Privacy Policy supplements the Company’s global and local data protection policies which set out the principles that apply to the use of personal information throughout our group. The policies and this Privacy Policy refer to all processing of your personal information.

This Privacy Policy is intended to help you understand why and how we may use your information. The lists and examples below are illustrative, non-exhaustive and not fully representative for every individual within our group. This Policy may be supplemented by additional policies or guidance ("Additional Policies"). Wherever such Additional Policies are in any respect inconsistent with this Policy, this Policy shall only apply to the extent that it is consistent, or may be made consistent, with that Additional Policy.

The information contained in this Privacy Policy applies to all partners, prospective, current and former employees, temporary and contract staff and third party contractors. Please note that this Privacy Policy does not form part of any contract of employment or other contract to provide services.


We shall at all times comply with the GDPR and all local data protection law (as may be applicable). This means that the personal data we hold about you must be:

  • Used lawfully, fairly and in a transparent way.
  • Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
  • Relevant to the purposes we have told you about and limited only to those purposes.
  • Accurate and kept up to date.
  • Kept only as long as necessary for the purposes we have conveyed to you.
  • Kept securely at all times.


Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Type of Personal Information Examples
Please note that the examples are illustrative and non-exhaustive

Information about you:

Name, address, date of birth, marital status, nationality, gender, photo and preferred language, details of any disabilities, work restrictions and/or required accommodations.

Information to contact you at work or home:

Name, address, telephone and email address.

Information about who to contact in case of an emergency (yours or ours):

Name, address, telephone, email address and their relationship to you.

Information to identify you:

ID, photographs, passport and/or driving license details, electronic signatures.

Information about your suitability to work for us and/or our clients:

References, interview notes, work visas ID information such as passport details and driving license information, records/results of pre-employment checks, including criminal record checks, credit and fraud checks.

Information about your skills and experience:

CVs, resumes and/or application forms, references, records of qualifications, skills,training and other compliance requirements.

Information about your terms of employment with us:

Letters of offer and acceptance of employment, your employment contract, location, billing and subscription information.

Information that we need to pay you:

Bank account details, certificate of non- bankruptcy, national insurance or social security numbers (where applicable), salary and benefits, expense allowances.

Information that we need to provide you with benefits and other entitlements:

Length of service information, health information, leave requests.

Information relating to your work travel expenses:

Bank account details, passport, driving license, vehicle registration and insurance details.

Information relating to your pension entitlements

Pensionable salary, pension base, annual pension accrual, pension benefits

Information to allow you to access our buildings and systems:

Computer or facilities access and authentication information, identification codes, passwords, answers to security questions, photographs, video images (including those captured via CCTV).

Information relating to your performance at work:

Performance assessments and ratings, leadership ratings, financial interests, directorships, targets, objectives, records of performance reviews, development records and/or notes of one to ones and other meetings, personal development plans, training recommended and completed, personal improvement plans, secondments, correspondence, reports

Information relating to sickness and absence management

Absence and time-keeping records, start and end date of reporting in sick, sick certificates, percentage of sickness and absence per employee, address where an employee is being treated (when different than home address)

Information relating to discipline, grievance and other employment related processes:

Interview/meeting notes or recordings, correspondence.

Information required to ensure your independence and the independence of our firm

Financial interests including publicly available debt, equity securities, tradable financial notes issued by banks, mutual funds, hedge funds, money market funds, unit investment trusts and other investment vehicles of our employees, their spouses (or spousal equivalent) and/or financial dependents.

Financial interests held through a financial product or investment agreement, owned by our employees their spouse (or spousal equivalent) and financial dependents such as underlying publicly available securities related to: (i) insurance policy investments;

(ii) retirement investments; (iii) investment club investments; (iv) investments included in trusts; and (v) discretionary accounts managed by others. Other financial relationships such as loans, brokerage relationships, deposits, insurance information. Information on family members’ employment relationships.

Brokers/investment accounts, deposits, credit cards, other loans, real estate interests, insurance policies, employer sponsored retirement savings plans, non-public investments


Some types of information are classified as ‘sensitive’ for the purposes of the GDPR and there are additional restrictions on how we may use and hold this information. Sensitive personal information is information that relates to a person’s:

  • Racial and ethnic origin;
  • Physical or mental health;
  • Genetic or biometric data;
  • Alleged or actual criminal convictions and proceedings.

The above are merely illustrations and we do not collect all of the above information. However we may, if absolutely necessary, be required to collect some information that may be classified as “sensitive”. Generally, it is necessary to obtain your consent before we can hold and use such information. However, we may hold and use such information without consent for limited statutory purposes such as monitoring compliance with our equal opportunities policies and health and safety rules, or if necessary to protect your vital interests, for legal claims, or in the public interest.

In any case, we will make clear the purposes for which we wish to use your sensitive information when it is being collected, and, if necessary, obtain your consent at that time.


We collect and maintain information as to whether you have a clean criminal record for purposes of complying with our legal and regulatory obligations as your employer. In doing so we have in place an appropriate policy and safeguards to maintain such information.


We collect personal data about YOU through the application and recruitment process, either directly from YOUor from other limited sources (for example, offline from previous employers or online an employment agency, Linkedin medium and/or other recommendations. We may sometimes collect additional information from third parties including former employers. We may also collect additional personal information in the course of job-related activities throughout the period of you working for us.


We are using Legitimate Interst as our legal basis for processing your personal data per Arcticle 6(1)(f) of the GDPR.

We will process your personal data in order to allow us to efficiently perform our contract with you and to enable us to comply with our legal obligations as your employer. In some cases we may use your personal data to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below (Permitted Purposes).

Purposes for which we need your personal information


Please note that these examples are illustrative and non-exhaustive.


  • To assess your suitability to work for us, a QuadCode company and/or an affiliated third party;
  • To perform requisition and applicant management activities;
  • To perform precision matching to job vacancies;
  • To conduct screening, assessments and interviews;
  • To maintain a library of correspondence;
  • To make offers and provide contracts of employment;
  • to communicate with you, and
  • To conduct pre-employment checks, including determining your legal right to work and carrying out criminal record and credit checks where applicable.

Human Resources ("HR"), finance and other business administration purposes:

  • Staffing, including resource planning, secondments, skills allocation, engagement management, recruitment, termination and succession planning;
  • Budgetary and financial planning and administration;
  • Organizational planning and development and workforce management, including monitoring the effectiveness of our equal opportunities policies and the fair and consistent treatment of staff members and job applicants;
  • Compensation, payroll, and benefit planning and administration, including salary, tax withholding, tax equalization, awards, insurance and pensions;
  • Workforce development, education, training and certification, maintaining up to date records of professional qualifications, memberships and continuing professional development programmes;
  • Performance management and performance rating details (including achievements and work history);
  • Problem resolution, including carrying out internal reviews, grievances, investigations, audits and disciplinary procedures;
  • Business travel and expense management;
  • Administration of use of company cars
  • To assist with Visa and submitting immigration applications for working permits for our employees and/or their close family members
  • To conduct business reporting and analytics;
  • Administration of flexible work arrangements;
  • Administration of employee enrolment and participation in activities and programmes offered to eligible employees, including matching donations to non-profit organizations, political action committee contributions, and wellness activities;
  • Promotional and marketing materials and activities, including quotes, photos and videos;
  • Work-related injury and illness, including the management of employee Health & Safety, and disabilities, sickness and absence management;
  • To provide HR helpdesk support and case management;
  • To communicate with you and to facilitate communication between you and other people (including voicemail, e-mail and electronic collaborations);
  • Compliance and compliance reporting, including conflict of interest and gifts and hospitality reporting;
  • Risk management;
  • Project Management;
  • Billing, time-keeping;
  • Monitoring and assessing compliance with our Staff Handbook, other policies and standards (e.g. the IT Code of Connection);
  • Training and quality purposes; and
  • In the event of a take-over or merger, providing information to a future purchaser of any part of the Company’s business.

Diversity & Inclusiveness (D&I)

  • Focus on diversity and inclusiveness in serving clients, developing people and playing a leadership role in communities.
  • Meeting D&I targets (i.e. regarding increasing the number of females and minority hires/promotions)

Security purposes:

  • Physical access control;
  • Authorizing, granting, administering, monitoring and terminating access to or use of the Company’s or third party facilities, records, property and infrastructure including communications services such as business telephones and email/internet use;
  • CCTV; and
  • Prevention and detection of crime

Information Technology ("IT") administration purposes:

  • IT Systems access control and use monitoring;
  • IT fault reporting, management and resolution;
  • Systems administration, support, development, management and maintenance.

Legal purposes:

  • To comply with our legal obligations, including anti-bribery and corruption, conflicts of interest and money laundering.
  • To keep a register of violations, incidents or personal data breaches.
  • In a take-over or merger, providing information to a future purchaser of the Company or any part of the Company’s business.

Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.

If you fail to provide personal information

If you fail to provide certain information when requested or request that we do not share your information with an affiliated third party company, we may not be able to perform our services and/or the contract we have entered into with you (such as assessing your job application and connecting you with the correct job vacancy etc.), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the purpose for which it has been collected. In such a case we shall notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


We generally do not use automated decision-making. If we use this procedure in individual cases, we will inform you of this separately.


We may share you data in the following circumstances, the following are examples of where and how your information may be transferred, but please note this is not an exhaustive list and that due to ongoing changes in our IT and/or operational infrastructure this may change at any time:

  • (i) We may share your data between the QUAD CODE Entities on a confidential basis in order to provide you with employment opportunities within the QUAD CODE Entities.
  • (ii) We may have to share your data with third parties, including third-party service providers and other entities within our group and/or affiliated entities, which provide us and the Quad Code Entities, services.
  • (iii) To travel agents/coordinators for the purpose of arranging business trips;
  • (iv) To our insurance company(ies) for the purpose of providing the car insurance for use of the company cars;
  • (v) To public authorities;
  • (vi) To our external accountants/auditors;
  • (vii) Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place;
  • (viii) group and/or affiliated entities which are looking to recruit a candidate of your caliber and qualifications for an open vacancy.

We require third parties to respect the security of your data and to treat it in accordance with the law.

International Transfers of Personal Information

When making transfers between the QUAD CODE Entities and/or to a third country, we will ensure that they are subject to appropriate security measures and safeguards as deemed appropriate, under GDPR and the relevant national and international laws. This may include entering into the appropriate contractual relationships to regulate any such transfers and safeguard any personal information transferred to them.

In particular, if a data transfer is required to a QUAD CODE Entity located in third country in order for us to be able to provide you with employment opportunity within the QUAD CODE Entities, we will, prior to proceeding with such transfer, provide you with more information on the particular data protection laws and regulations regulating the collection and processing of data in that particular jurisdiction.

All entities and offices within QUAD CODE will ensure an adequate level of protection for your personal data at all times.

If you want to obtain further information on any data transfers mentioned above please contact us through the points of contact listed in the section OUR CONTACT DETAILS below.


We have put in place measures to protect the security of your information. Details of these measures are available upon request. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized 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 Human Resources Department.

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.


How long will we use and keep your information

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 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 unauthorized 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 requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further Policy to you.

Once you are no longer an employee or third party contractor of the Company we will retain and securely destroy your personal information for a period of 5 years (which may be extended under certain circumstances to 7) in accordance with our data retention policy or as may be required by applicable laws and regulations.


Under certain circumstances, by law you have the right to:

  • Request access to your personal information.
  • Request correction of the personal information that we hold about you.
  • Request erasure of your personal information.
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
  • Request the restriction of processing of your personal information.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Human Resources Department in writing.


We have appointed a data protection officer (DPO) to oversee compliance with this privacy Policy. If you have any questions about this privacy Policy or how we handle your personal information, please contact the DPO. You have the right to make a complaint at any time to the Commissioner for the protection of personal data’s Office, the Cyprus supervisory authority for data protection issues.


We reserve the right to update this privacy Policy at any time, and we will provide you with a new privacy Policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.


If you have any questions about this Privacy Policy, please contact our DPO officer at

To enable us to process your request we may require that you provide us with proof of your identity, such as by providing us with a copy of a valid form of identification. This is to ensure that we appropriately protect the personal data we hold from unauthorized access requests and comply with our security obligations.

Last updated: April 2024

Data request

In order to download your personal data, please specify the email that you disclosed to us when you applied for a vacancy, and we will provide you with a copy of your personal data currently stored in our systems in machine-readable format.

Processing of your request may take up to 30 business days. If you no longer have access to the email address disclosed during the application process, please contact us at:

Delete data

Deletion of your personal data is permanent. In order to DELETE your personal data currently stored in our system, you can do so by specifying the email that you indicated when applying for a vacancy. You will receive an email with further information on the matter and a confirmation link to your request. By proceeding and clicking the link in the email, your personal data will be permanently deleted from our system.

Processing of your request may take up to 30 business days. If you no longer have access to the email address disclosed during the application process, please contact us at: