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Codex Limited has implemented this policy statement to provide guidance to all interested parties on our approach to managing personal information throughout our organization, with full consideration for our obligation toward relevant data protection legislation, including EU-GDPR. The company management system has been developed to include appropriate measures determined by the ISO 27001 Standard.


Where appropriate, Codex has determined specific mechanisms to control how personal data is managed throughout operational and support processes, based on the following precepts with consideration for Article 5 of the GDPR directive (Principles relating to the processing of personal data);


  1. That personal information gathered is only done so for the legitimate purposes of our business, including where necessary, legal and regulatory purposes.
  2. Only the minimum amount of information necessary for effective operations is processed.
  3. Codex does not process any children’s information through any business process.
  4. No Codex business process requires that information is gathered directly from children.
  5. Codex ensures that we only process relevant and adequate personal information throughout operations.
  6. That personal information is processed in a fair and lawful manner.
  7. Codex maintains an inventory of categories of personal information processed by the organization.
  8. That all personal information is kept accurate and up-to-date.
  9. All personal information is only retained for as long as is necessary for legal or regulatory reasons or for legitimate organisational purposes, ensuring it’s timely and appropriate disposal.
  10. That in all circumstances, the rights of natural persons to their personal information is respected.
  11. Adequate resources have been allocated to ensuring that all personal information processed and stored by Codex is done so in a secure operational environment.
  12. That transferring personal information outside our national boundary is only done in circumstances where it can be adequately protected.
  13. Where we are providing our goods and services to EU citizens across national boundaries, Codex ensures that appropriate regulatory aspects are addressed.
  14. Codex does not currently carry out any operations where the application of the various exemptions allowable by data protection legislation is required.
  15. We have developed our management system to provide for the formal management of personal information, which provides for all measured documented herein.
  16. Codex has identified internal and external interested parties and the degree to which they are involved in the governance of the organisation’s management system relevant to personal information.
  17. Top management has appointed management representatives with specific responsibility and accountability for personal information within the management system.
  18. Appropriate records of processing of personal information are maintained throughout operations.
  19. By interacting with marketing emails sent to you from Codex, you could be subjected to retargeted communications through the contact details you have submitted to us.



Codex has implemented an Internal Audit Programme to ensure the ongoing suitability, conformity and continual improvement of the management system is assured. The management system has the full support of all interested parties. All operational and support processes are within the scope of the management system. All personnel have been provided with a copy of this document, and it remains available in the Codex document system for further reference. This policy statement is also published to the company website


For all data privacy questions & queries please contact Gerard Healy at 

Should you wish to escalate the query further after consulting with the member of a Codex team, please contact Phil Byrne at


Ref: POL 05-02

Company Policies category