GDPR & Data Handling Brief

Xorlogics combines EU-based technical and delivery leadership with offshore engineering scale. Our hybrid model is designed to help European clients benefit from scalability and flexibility while maintaining data handling practices aligned with core GDPR principles, including accountability, data minimisation, security, confidentiality, and controlled international transfers.

1. EU-Led Governance and Client Interface

For European engagements, Xorlogics can provide local commercial, delivery, and technical leadership through its Belgium and UK offices. This helps keep project governance, requirements analysis, solution design, delivery oversight, and client communication close to the customer environment, with clearer accountability and stronger operational control.

2. Processor Controls and Contractual Protections

Where Xorlogics processes personal data on behalf of a client, the engagement should be governed by a suitable data processing agreement defining documented instructions, confidentiality obligations, appropriate security measures, sub-processor controls, and support for the client's compliance obligations.

3. Controlled Offshore Access and International Transfers

Where personal data is accessed or processed outside the EEA, transfer arrangements should be documented using a lawful GDPR transfer mechanism and supported by appropriate technical and organisational safeguards. Offshore access should be limited to what is operationally necessary and aligned with the client's contractual and security requirements.

4. Security and Data Minimisation by Design

The hybrid model supports secure delivery through least-privilege access, controlled environments, secure connectivity, logging, and minimising the volume of personal data shared with offshore teams wherever possible.

5. Practical Delivery Model

Xorlogics' EU offices can contribute analysis, design, project management, technical guidance, coordination, and client communication, while offshore teams can provide core engineering execution, QA, DevOps, and dedicated development capacity. Selected offshore team members may also work onsite when needed to improve business understanding, team alignment, and delivery quality.

6. Important Compliance Note

GDPR compliance depends on the details of each engagement, including the type of data involved, the systems used, the roles of the parties, the countries involved, and the safeguards implemented. This brief summarises Xorlogics' operating approach and compliance framework and should be used alongside project-specific contracts, security measures, and data transfer documentation.

For data protection enquiries, please contact us at info@xorlogics.com. You may also wish to review our Privacy Policy.