Privacy Policy



1.1 Everyone has rights with regard to the way in which their personal data is handled. During the course of our activities we will collect, store and process personal data about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations. In this policy references to we, us and our, are to Edaptive Group Limited and any subsidiary of Edaptive Group Limited, including Rich Insight Portfolio Limited and Emanaged Limited (the ‘Group’).

1.2 Data users are obliged to comply with this policy when processing personal data on our behalf. Any breach of this policy may result in disciplinary action.


2.1 We may be required to handle personal data about current, past and prospective suppliers, customers, partners and other contacts. The personal data, which may be held on paper or on a computer or other media, is subject to certain legal safeguards. We are regulated under the Data Protection Act 2018 and the General Data Protection Regulation (the ‘GDPR’) which applies across the European Union (including in the United Kingdom) and we are responsible in respect of that personal data for the purposes of those laws (the Act).

2.2 This policy and any other documents referred to in it sets out the basis on which we will process any personal data we collect from data subjects, or that is provided to us by data subjects or other sources.

2.3 This policy does not form part of any employee’s contract of employment and may be amended at any time.

2.4 This policy sets out rules on data protection and the legal conditions that must be satisfied when we obtain, handle, process, transfer and store personal data.

2.5 The Data Protection Compliance Manager is responsible for ensuring compliance with the Act and with this policy. That post is held by Richard Hurtley, Director, 020 3287 7710, Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Compliance Manager.


3.1 Data is information which is stored electronically, on a computer, or in certain paper-based filing systems.

3.2 Data subjects for the purpose of this policy include all living individuals about whom we holds personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal information.

3.3 Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and behaviour.

3.4 Data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They are responsible for establishing practices and policies in line with the Act. We are the data controller of all personal data used in our business for our own commercial purposes.

3.5 Data users are all staff including our employees temporary and agency workers, other contractors, interns and volunteers whose work involves processing personal data. Data users must protect the data they handle in accordance with this data protection policy and any applicable data security procedures at all times.

3.6 Data processors include any person or organisation that is not a data user that processes personal data on our behalf and on our instructions. Staff and employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on our behalf.

3.7 Processing is any activity that involves use of the 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, storing, erasing or destroying it. Processing also includes transferring personal data to third parties.

3.8 Special Category personal data includes information about a person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning  health  or sexual life or sexual orientation. Special Category personal data can only be processed under strict conditions, including a condition requiring the express permission of the person concerned.


4.1 Anyone processing personal data must comply with the six principles under the GDPR. These provide that personal data must be:

(a) Processed lawfully, fairly and in a transparent manner in relation to the data subject (‘lawfulness, fairness and transparency’);

(b) Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall, in accordance with Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’);

(c) Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);

(d) Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);.

(e) Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (‘storage limitation’);

(f) Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (‘integrity and confidentiality’).


5.1 The Act is not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject.

5.2 For personal data to be processed lawfully, they must be processed on the basis of one of the legal grounds set out in the GDPR. These include:

5.2.1. to comply with our legal and regulatory obligations;

5.2.2. for the performance of our contract with the data subject or to take steps at the data subject’s request before entering into a contract;

5.2.3. for our legitimate interests or those of a third party; or

5.2.4. where we have consent from the data subject.

When Special Category personal data is being processed, additional conditions must be met. When processing personal data as data controllers in the course of our business, we will ensure that those requirements are met.


6.1 In the course of our business, we may collect and process the personal data set out in the Schedule 1. This may include data we receive directly from a data subject (for example, by completing forms or by corresponding with us by mail, phone, email or otherwise) and data we receive from other sources (including, for example, business partners, sub-contractors in technical, payment and delivery services, credit reference agencies and others).

6.2 We will only process personal data for the specific purposes set out in the Schedule 1 or for any other purposes specifically permitted by the Act. We will notify those purposes to the data subject when we first collect the data or as soon as possible thereafter.


7.1 If we collect personal data directly from data subjects, we will inform them about:

(a)  The purpose or purposes for which we intend to process that personal data.

(b)  The types of third parties, if any, with which we will share or to which we will disclose that personal data.

(c)  The means, if any, with which data subjects can limit our use and disclosure of their personal data.

7.2 If we receive personal data about a data subject from other sources, we will provide the data subject with this information as soon as possible thereafter.

7.3 We will also inform data subjects whose personal data we process that we are the data controller with regard to that data, and who the Data Protection Compliance Manager is.


8.1 We will only collect personal data to the extent that it is required for the specific purpose notified to the data subject.


9.1 We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.


10.1 We will not keep personal data longer than is necessary for the purpose or purposes for which they were collected. We will take all reasonable steps to destroy, or erase from our systems, all data which is no longer required.


11.1. Under the GDPR data subjects have a number of important rights free of charge. In summary, those include rights to:

11.1.1. access to their personal data and to certain other supplementary information (see also Clause 15)

11.1.2. require us to correct any mistakes in their personal data which we hold (see also Clause 9)

11.1.3. require the erasure of personal data concerning them in certain situations

11.1.4. receive personal data concerning them which you have provided to us and have the right to transmit such data to a third party in certain situations.

11.1.5. object at any time to processing of personal data concerning them for direct marketing

11.1.6. object to decisions being taken by automated means which produce legal effects concerning them or similarly significantly affect them

11.1.7. object in certain other situations to our continued processing of their personal data

11.1.8. otherwise restrict our processing of their personal data in certain circumstances.

11.2. Employees will need to refer any request from a data subject to exercise any of the above rights to the Data Protection Compliance Manager as soon as possible.


12.1 We will take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data].

12.2 We will put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.

12.3 We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:

(a)  Confidentiality means that only people who are authorised to use the data can access it.

(b)  Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.

(c)  Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on Rich Insight Portfolio’s central computer system instead of individual PCs.

12.4 Security procedures include:

(a)  Entry controls. Any stranger seen in entry-controlled areas should be reported.

(b)  Secure lockable desks and cupboards. Desks and cupboards should be kept locked if they hold confidential information of any kind.

(c)  Methods of disposal. Paper documents should be shredded. Digital storage devices should be physically destroyed when they are no longer required.

(d)  Equipment. Data users must ensure that individual monitors do not show confidential information to passers-by and that they log off from their computer when it is left unattended.


13.1 We may transfer any personal data we hold to a country outside the European Economic Area (”EEA”), provided that one of the following conditions applies:

(a)  The country to which the personal data are transferred ensures an adequate level of protection for the data subjects’ rights and freedoms.

(b)  The data subject has given his consent.

(c)  The transfer is necessary for one of the reasons set out in the Act, including the performance of a contract between us and the data subject, or to protect the vital interests of the data subject.

(d)  The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims.

(e)  The transfer is authorised by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of the data subjects’ privacy, their fundamental rights and freedoms, and the exercise of their rights.

13.2       Subject to the requirements in Clause 12.1 above, personal data we hold may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. That staff maybe engaged in, among other things, the fulfilment of contracts with the data subject, the processing of payment details and the provision of support services.


14.1 Personal data will be shared within the Group.

14.2      We may also disclose personal data we hold to third parties:

(a)  In the event that we sell or buy any business or assets, in which case we may disclose personal data we hold to the prospective seller or buyer of such business or assets.

(b)  If we or substantially all of our assets are acquired by a third party, in which case personal data we hold will be one of the transferred assets.

14.3       If we are under a duty to disclose or share a data subject’s personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with the data subject or other agreements; or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

14.4 We may also share personal data we hold with selected third parties for the purposes set out in the Schedule 1.


15.1 Data subjects must make a formal request for information we hold about them. This must be made in writing. Employees who receive a written request should forward it to the Data Protection Compliance Manager immediately.

15.2 When receiving telephone enquiries, we will only disclose personal data we hold on our systems if the following conditions are met:

(a)  We will check the caller’s identity to make sure that information is only given to a person who is entitled to it.

(b)  We will suggest that the caller put their request in writing if we are not sure about the caller’s identity and where their identity cannot be checked.

15.3 1.1.     Our employees will refer a request to the Data Protection Compliance Manager for assistance. Employees should not be bullied into disclosing personal information.


16.1 We reserve the right to change this policy at any time. Where appropriate, we will notify data subjects of those changes by mail or email.