At Elite, we take our obligations to you and the information we hold about you seriously.
As of the 25th May 2018 the data protection laws changed and the General Data Protection Regulation was introduced. Whilst you shouldn’t notice a difference in the way we look after you we’d like to explain what it means for you. All businesses now need to be much clearer about the data they now hold about you and how they intend to use that information. We’d like to ensure you know the same for Elite and can influence that data and its use accordingly.
For reference, when it says ‘Elite’, ‘we’, ‘our’ or ‘us’, it refers to Elite Management & Consultancy and where the terms ‘you’, ‘yours’ or ‘your’ are used, it means the individual who is using, has expressed an interest in using or has used our services (including contacting us regarding the above our any other aspect of our business).
As a current customer, we hold the information you we need to deliver our services to you. Over time, if you no longer use our services (or no longer do so), we will continue to hold some information but you will always be able to find out what we have and assist us in how we use it.
Elite is the Controller of the information. This is not only the information you actively provide to us but also information that may be collected passively when you interact with any of our online services such as our website, telephony and messaging services or electronic portals.
Collection Of Your Data
There are a number of ways in which we collect your information. These may include when you;
- Contact us by telephone, email, electronic messaging (such as SMS, MMS or live chat tools) or post
- Visit our website (regardless as to whether you submit information using a data capture form)
- When someone refers you as someone who may be interested in using our services
We may also receive information about you from third parties not limited to websites or introducers
We’ll never keep more information about you than we need to help us provide services to you both now and in the future.
The various types of information we collect will often depend on the manner in which the information was provided to us. When it comes directly from you or is given to us on your behalf, we call that Active Provision. Examples of this would be:
- When you submit data to us through an electronic or written data capture form
- When you phone us, email us, communicate via electronic messaging (such as SMS or live chat tools) or write to us
In addition, we would also class information provided about you but not from you as Active Provision. This would include;
- Data we receive when someone refers you for our products and services
- Data from other organisations (such as but not limited to agencies and clients) who in adhering to GDPR have obtained your permission to share information about you with us though in receiving that data the ownness remains on you and the providing party to validate that adherence
When information comes from your activity but does not require you to submit the information to us directly we call that Passive Provision. Examples of this would be:
- When you utilise electronic mediums to access our services (such as electronic portals)
- Phone call data such as your telephone number, inbound / outbound caller number, time and duration of the call, and information about the device you used to contact us
- Payment and transaction data of funds received and paid, the origins and destinations of those funds and all statutory obligations against those payments such as but not limited to taxable contributions
- Device Data (IP address, device make and manufacturer, browser information and other similar identifying information required from your devices to communicate with websites and applications on the internet)
We also monitor, record (including calls), store and use the communications we have directly with you to improve the quality of our service delivery and/or for training, operational and compliance purposes
How We May Use Your Data
The ways in which we use the information we hold about you varies but it will always be motivated by a desire to assist with current service provision and services we may provide in the future. For example;
- To determine your eligibility and suitability for our services
- To process your application and enable you to receive funds from Elite
- To respond to any questions or complaints you may have regarding our services
- To send you details of products, services, special offers and rewards that we think will be of interest to you.
- To carry out market research regarding our service provision and that you may have received elsewhere and feedback about your preferences
- To provide competitions
If you wish to withdraw your consent for us to use your data, please just let us know by emailing us or writing to us using the information below. We will then apply your instruction although any prior activity undertaken with your consent will remain legitimate and any financial data we are obliged to retain will be unaffected.
There may also be instances where we provide information to and receive information from third parties in respect to the use of our services but in every instance our priority remains ensuring that we treat your information in accordance with your preferences and interests.
Sharing Your Data
There will be times that we need to provide information to others. We provide information about you:
- To our employees so they can assist with any questions or complaints
- To any marketing agencies tasked with creating marketing materials, special offers and promotions that have been designed with your interests in mind
- We may share your information to comply with legal and regulatory obligations to protect or enforce our rights or that of a third party such as analysing activity in responding to requests from courts and enforcement authorities
Where we share your personal data with another company insofar as we can, we make sure that they respect your data protection rights too.
We won’t pass on your personal information to third parties except in accordance with this policy or where we are required to disclose that information in order to comply with legal and / or regulatory requirements.
Protecting Your Data
We take the security of your data very seriously and we ensure that it is held using robust security methods. Standard protocols and in place for information sent over unprotected communications paths such as the internet. Although we secure your information upon receipt, Elite cannot be responsible for its security whilst being transmitted.
Our standard data security protocols include:
- Infiltration testing
- Protecting our systems from unauthorised access and malicious traffic
- Training for employees on security and privacy
- Encryption of data where appropriate
- Internal policies setting out our data security approach supported by training of all employees
We store your data safely for the minimum time to operate services provided to you by Elite and/or based on the reasons that we process your personal data. Afterwards it’ll either be destroyed or anonymised.
When determining the relevant time we store information for, we review this based upon the following:
- Standard recommendations as set out by the Data Protection Authority (UK)
- Dispute resolution that may arise even after service use has ended
- Any legal obligation(s) that mandate the minimum periods for which we hold data
Unless you ask us not to, we store your details for up to one year after your initial enquiry. This enables us to recognise you should you re-enquire and to contact you with a view to reviewing your potential interest in our services.
Where we have undertaken a financial transaction with you, we need to provide an audit trail for this transaction. In this instance we would retain records of this transaction for five years.
The rights governing both recommended and statutory requirements around the use of your data will be standard across may of the businesses of whom you are a customer and / or user. We have shown them as the following.
- 1. The right to be informed
- 2. The right of access
In line with data protection regulations, you have access to all of the information that we hold about you and can request this at any time. We do not charge for providing you with this information though depending on the nature of your request we ask that you allow up to 30 days for us to provide you with the information that you have asked for. You can make your request using the contact information below.
- 3. The right to rectification
We try to ensure that any information we hold about you is correct and complete. However, if you identify that this is not the case and the data we hold is inaccurate or incomplete please let us know and we’ll amend accordingly.
- 4. The right to erasure (the right to be forgotten)
You may request the deletion or removal of your information. If Elite are unable to satisfactorily demonstrate why this data needs to be remain, it must be erased with no capacity for it to be retrieved retrospectively.
- 5. The right to restrict processing
Where your data is held you may still request for a restriction in its use so that it can not be processed for use in the future. Any data where processing has been restricted will be held separately from data where processing has not been restricted.
- 6. The right to data portability
The data Elite hold about you is still your personal data. Therefore, you are able to request, receive and subsequently reuse this for your own purposes including different services. Your data will be provided to you in a manner that should easily enable you to communicate part of all of it to any third party.
- 7. The right to object
You can object to the manner in which your data is used and in doing so specify your preferences for the use of your data and how its use impacts you.
- 8. Rights in relation to automated decision making and profiling
In delivering our service to you there may be occasions where our systems make ‘decisions’ based upon the data we hold. These decisions will be used to assist with providing our services to you but will always be supervised and used with human intervention.
All of these rights are current and Elite are accountable for adherence to them.
Whilst the majority of our communications to you are for information in respect to your use of our services, we may from time to time use them for marketing purposes. Any services marketed will be provided or facilitated by Elite with a genuine informed belief that the services offered should be of interest.
We may contact you by telephone, email or other electronic messaging services. Your use of any of our services is taken as consent to communicate to you in this manner. If you wish to remove this consent please let us know and we will apply this non-consent immediately.
If you need to contact us you can do so using the following contact information.
You can write to us at:
Elite Management & Consultancy Limited
44 Old Hall Street
You can send an email to firstname.lastname@example.org if you are dissatisfied with any of the information above or still have further questions, we would ask you to contact us. If for any reason we are unable to satisfy your request, you are able to escalate your concerns to the Information Commissioner’s Office (ICO).