Policies

ELITE SERVICES CORPORATION LTD provides security services to the construction, healthcare, retail, residential and leisure sectors. The Company provides the highest levels of customer service and respects the customer’s right to be involved in the improvement of his contract with the Company. The Company seeks to improve its market share in the industry through diligent pursuit of quality control and human resources development programs.

Provide a trained, disciplined and professional workforce motivated to offer quality service to our customers.  ELITE SERVICES CORPORATION LTD has plans to be assessed by an accredited assessment body, to BS.EN.ISO 9001: 2015 and BS 7499 together with other relevant BS codes of practice.

The Company also ensure that its workforce is screened to BS 7858 We are committed to quality management in all aspects of the business. The purpose of this manual is to present the organisation's Quality Management system to all personnel, giving the guidance essential for the effective application of Quality Control. The contents serve as a basic reference to policies, processes, and procedures, together with work instructions (where necessary) outlining the activities and responsibilities, which a person holding a company appointment is expected to undertake as a normal part of his/her duties.

The Managing Director shall determine the criteria and methods to ensure that both the operation and control of the processes are effective. It is the responsibility of the Managing Director to ensure the availability of resources and information necessary to support the operation and monitoring of the processes. ELITE SERVICES CORPORATION LTD's Quality policy is a framework for its management system quality objective. The organisation shall monitor measure and analyze the processes, ensuring that actions are implemented to achieve planned results and to continually improve their effectiveness.

Our organisational goals are to ensure that the changes required within our documented management system will meet the requirements of BS EN ISO 9001:2015, written to all Standards, Codes of Practice and Schedules as required by ACOPS and regs, which are performed in a managed methodical way to ensure that the system is fully understood and implemented throughout the company. ELITE SERVICES CORPORATION LTD will make this Policy available to all stakeholders, shareholders, staff and the general public on request. 

Approved

Managing Director

ELITE SERVICES CORPORATION LTD

This policy is reviewed on 01/01/2024

ELITE SERVICES CORPORATION LTD Provide security guarding key holding and intruder alarm response services to residential and business premises. At ELITE SERVICES CORPORATION LTD the top management is committed to providing adequate control of the health and safety risks arising from our work activities under the Health and Safety at Work etc. Act 1974; by consulting with its employees on matters affecting their health and safety at the workplace. ELITE SERVICES CORPORATION LTD ensures the safe handling and use of substances and provides adequate information instruction and supervision for employees.

ELITE SERVICES CORPORATION LTD is committed to ensuring that all employees are competent to do their tasks and to give them adequate training. ELITE SERVICES CORPORATION LTD as an employer understand its responsibility to report certain serious workplace accidents, occupational diseases and specified dangerous occurrences (near misses) under RIDDOR - Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013. ELITE SERVICES CORPORATION LTD is committed to preventing accidents and cases of work-related ill health to maintain safe and healthy working conditions;

Therefore, what we provide, so far reasonably practicable.

• A safe system of work.
• Safe plant and equipment.
• Safe means of handling and transporting articles, substances and people
• Adequate training, instruction, information and supervision
• A safe place of work with safe access and egress.
• A safe and healthy environment.
• Adequate welfare facilities.

Management at ELITE SERVICES CORPORATION LTD is committed to ensuring, so far as is reasonably practicable, that the way we carry out our security operations does not affect the Health and Safety of persons who are not our employees, for example, visitors and contractors.

It is also recognised that where we produce articles and substances for use at work or we erect or install any plant or equipment, we have a duty to ensure the Health and Safety of those who use them and make available all the required information for their Health and Safety.

The Managing Director shall review this policy annually or following significant changes.

ELITE SERVICES CORPORATION LTD

This policy is reviewed on 01/12/2023

The top management of ELITE SERVICES CORPORATION LTD is aware of the impact its business operations have on the environment both on a local and global aspect.

ELITE SERVICES CORPORATION LTD recognise that in our day-to-day operations, we inevitably impact the environment in a number of ways both on a local and global aspect and are committed to reducing that impact through continual improvement in our environmental performance. We would implement the policy of recycling, reduction in the generation of waste and the promotion of environmental awareness based on the requirements of IS0 14001: 2015.  ELITE SERVICES CORPORATION LTD is committed to fulfilling its legal and other obligations and to the prevention of pollution in context with our organisation.

This is achieved through our Management System which meets the requirements of BS EN ISO 14001:2015 including aspects specific to the service industry and also ensures our business processes are carefully monitored, measured and controlled to promote a continual improvement in our environmental performance.

It is therefore our policy to adopt procedures and practices that;

• Does not damage our environment.
• Does not restrict the enjoyment of the environment by others.
• Promote sustainable improvements (where we have an influence) that consider the effects on the environment.
• We will minimise the amount of waste in landfills through the adoption of the waste hierarchy: ELIMINATE, REDUCE, REUSE and RECYCLE.
• We are committed to continual improvement in our environmental performance, through the implementation of our EMS, and the establishment of measurable environmental objectives and targets. These will be documented, implemented, maintained, monitored, and reviewed.
• Put controls in place to protect the environment from any significant environmental aspects and impacts arising from our work activities.
• Promote a sustainable approach to business, in partnership with our clients and other stakeholders by conserving energy, minimising consumption, preferring low-pollution materials, maximising efficiency and implementing the Waste Management Hierarchy.
• We will support this policy by implementing the following procedures:
• All wastepaper, junk mail, documentation etc. must be returned to the office via your supervisor for re-cycling in the most appropriate way that does not compromise the integrity of our clients, employees or company.
• Arrange for all printer cartridges, toners etc. to be returned to the supplier or designated agent in the envelopes provided for re-cycling. Promote the use of recycling banks for bottles, cans, paper and other waste materials that employees may bring into their place of work.
• Ensure any packaging supplied with any equipment is disposed of in methods that support this policy Seek professional advice to adopt further practices that result in generating less paper and less waste.

This policy is promoted throughout our company and communicated to all staff and organisations working for or on our behalf via effective training and leadership.

Employees and other organisations are expected to cooperate and assist in the implementation of this policy, whilst ensuring that their own work, so far as is reasonably practicable, is carried out without risk to themselves, others, or the environment. ELITE SERVICES CORPORATION LTD fully accepts its responsibility to protect the environment in all its business activities by adopting best practice industry standards and guidelines.

It is ELITE SERVICES CORPORATION LTD’s responsibility to ensure the Management System functions correctly and its effectiveness is maintained through monitoring, control, audit and review.

The Managing Director shall review this policy annually or following significant changes.

ELITE SERVICES CORPORATION LTD

This policy is reviewed on 01/12/2023

Operating in a responsible and sustainable manner is important to our company.

Although at ELITE SERVICES CORPORATION LTD we run our business activities in line with the expectations of our diverse stakeholders, we also see corporate responsibility as a discipline that helps us to manage risks and maximise the opportunities presented to us in a changing global environment. We take our corporate responsibility seriously within our company as an employer, provider, investor and consumer. We are committed to understanding, monitoring and managing our social, environmental and economic impact to enable us to contribute to society’s wider goal of sustainable development. We aim to demonstrate these responsibilities through our actions and within our corporate policies.

We focus our CSR activities on the following key impact areas:

Workplace our ability to deliver world-class products is dependent on a talented, engaged workforce in all of the countries in which we operate. To this end, we are focused on making ELITE SERVICES CORPORATION LTD a place where people feel supported, can develop their skills, and have a clear understanding of our business objectives. We are committed to ensuring that our entire business is conducted according to rigorous professional, ethical and legal standards.

Additionally we:

Operate an equal opportunities policy for all present and potential future employees

Offer our employees clear and fair terms of employment and provide resources to enable their continual development

Maintain a clear and fair employee remuneration policy and maintain forums for employee consultation and business involvement.

Health & Safety

We shall provide, and strive to maintain, a clean, healthy and safe working environment providing a workplace where our employees feel safe is not only a legal obligation, but a fundamental factor in building their engagement with the company. Through management intervention, awareness campaigns and a culture that encourages employees to raise concerns about workplace safety, we aim to reduce the frequency of accidents.

Our Health & Safety department challenges and develops cooperation between all managers and employees to ensure health and safety management is embedded into management and business processes. This is supported by our Health & Safety Policy.

Marketplace We are in business to deliver value to our customers. All that we do is geared to providing world-class services and products and the best possible customer experience. We have a passion for excellence and we take pride in our ability to solve our customers’ problems, focusing on delivering innovative solutions in a timely manner. We aim for true customer satisfaction by understanding our clients’ needs and building partnerships.

Environment We recognise the importance of understanding the impact of our activities on the environment and we are developing an environmental program to demonstrate and benchmark our commitment. The environmental program addresses pollution control of chemicals, energy and water efficiency and waste reduction, all of which are subject to continuous review.

The Program also seeks to reduce the impact of our global carbon footprint and we will achieve this by monitoring carbon emissions and reporting them on an annual basis.

Community

We are committed to making a sustainable positive impact on the communities in which we operate. We aim to make a distinctive contribution to inequality and social development through the establishment of effective partnerships and programs that make the best use of the energies and skills of our employees. We support our employees in fundraising for charities and voluntary work, recognising both the benefit to the community and to the employees themselves. We also regularly choose relevant charities and sponsorships from within the communities we are involved with.

The Managing Director shall review this policy annually or following significant changes.

ELITE SERVICES CORPORATION LTD

This policy is reviewed on 01/12/2023

This statement is made under Section 54 of the Modern Slavery Act 2015. It sets out the steps that ELITE SERVICES CORPORATION LTD has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern Slavery encompasses slavery, servitude, human trafficking and forced labour. ELITE SERVICES CORPORATION LTD has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Our Policies

We operate several internal policies to ensure that we are conducting business ethically and transparently.

These include:

Anti-Slavery Policy.

This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help.

Recruitment Procedure.

We operate a robust recruitment process, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.

Whistle-blowing Policy.

We operate a whistle-blowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.

Our Suppliers

ELITE SERVICES CORPORATION LTD operates a Procurement Procedure and maintains an Approved Supplier List.

We conduct due diligence on all suppliers before allowing them to become an approved supplier. We require that they confirm to us that:

• They have taken steps to eradicate modern slavery within their business
• They hold their suppliers to account over modern slavery

Training

We regularly brief all relevant management and staff members and ensure that our policies reach every employee so that they understand the signs of modern slavery and what to do if they suspect that there is any risk of it taking place within any area of our business or our supply chain. As partner members, we will work with the Supply Chain Sustainability School to promote the material available to educate the industry on modern slavery.

Our Performance Indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

• No reports are received from employees, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
• We achieve a level of communication and personal contact with every employee and their understanding of, and compliance with, our expectations regarding modern slavery.

ELITE SERVICES CORPORATION LTD will make this Policy available to all stakeholders, shareholders, staff and the general public on request.

The Managing Director shall review this policy annually or following significant changes.

ELITE SERVICES CORPORATION LTD

This policy is reviewed on 01/12/2023

1. Introduction

This Policy sets out the obligations of ELITE SERVICES CORPORATION LTD Limited, (“ELITE SERVICES CORPORATION LTD”) regarding data protection and the rights of employees clients, staff and other individuals (“data subjects”) in respect to their personal data under EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”); an identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

This Policy sets ELITE SERVICES CORPORATION LTD’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by ELITE SERVICES CORPORATION LTD, its employees, agents, contractors, or other parties working on behalf of ELITE SERVICES CORPORATION LTD.

ELITE SERVICES CORPORATION LTD is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

2. The Data Protection Principles

This Policy aims to ensure compliance with the GDPR. The GDPR sets out the following principles with which any party handling personal data must comply. All personal data must be:

• Processed lawfully, fairly, and in a transparent manner about the data subject.
• 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 not be considered to be incompatible with the initial purposes.
• Adequate, relevant, and limited to what is necessary for the purposes for which it is processed.
• Accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay.
• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is 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, subject to the implementation of the appropriate technical and organisational measures required by the GDPR to safeguard the rights and freedoms of the data subject.
• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and accidental loss, destruction, or damage, using appropriate technical or organisational measures.

3. The Rights of Data Subjects

The GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):

• The right to be informed (Part 12).
• The right of access (Part 13);
• The right to rectification (Part 14);
• The right to erasure (also known as the ‘right to be forgotten’) (Part 15);
• The right to restrict processing (Part 16);
• The right to data portability (Part 17);
• The right to object (Part 18); and
• Rights concerning automated decision-making and profiling (Parts 19 and 20).

4. Lawful, Fair, and Transparent Data Processing

The Regulation seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The Regulation states that processing of personal data shall be lawful if at least one of the following applies:

1. The data subject has given consent to the processing of his or her data for one or more specific purposes;
2. Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject before entering into a contract;
3. Processing is necessary for compliance with a legal obligation to which the controller is subject;
4. Processing is necessary to protect the vital interests of the data subject or another natural person;
5. Processing is necessary for the performance of a task carried out in the public interest or the exercise of official authority vested in the controller;
6. Processing is necessary for the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

5. Specified, Explicit, and Legitimate Purposes
   • ELITE SERVICES CORPORATION LTD collects and processes the personal data set out in Part 21 of this Policy. This includes:
     • Personal data collected directly from data subjects; and Personal data obtained from third parties.
   • ELITE SERVICES CORPORATION LTD only collects, processes, and holds personal data for the specific purposes set out in Part 21 of this Policy (or for other purposes expressly permitted by the GDPR).
   • Data subjects are kept informed at all times of the purpose or purposes for which ELITE SERVICES CORPORATION LTD uses their personal data. Please refer to Part 12 for more information on keeping data subjects informed.
6. Adequate, Relevant, and Limited Data Processing

ELITE SERVICES CORPORATION LTD will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 5, above, and as set out in Part 21, below.

7. Accuracy of Data and Keeping Data Up-to-Date
   • ELITE SERVICES CORPORATION LTD shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part 14, below.
   • The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

8. Data Retention
   • ELITE SERVICES CORPORATION LTD shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.
   • When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.
   • For full details of ELITE SERVICES CORPORATION LTD’s approach to data retention, including retention periods for specific personal data types held by ELITE SERVICES CORPORATION LTD, please refer to our Data Retention Policy.
9. Secure Processing

ELITE SERVICES CORPORATION LTD shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 22 to 27 of this Policy.

10. Accountability and Record-Keeping
    • ELITE SERVICES CORPORATION LTD’s Data Protection Officer is the company HR office and can be contacted at the registered address. The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, ELITE SERVICES CORPORATION LTD’s other data protection-related policies, and with the GDPR and other applicable data protection legislation.
    • ELITE SERVICES CORPORATION LTD shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
      • The name and details of ELITE SERVICES CORPORATION LTD, its Data Protection Officer, and any applicable third-party data processors;
      • The purposes for which ELITE SERVICES CORPORATION LTD collects, holds, and processes personal data;
      • Details of the categories of personal data collected, held, and processed by ELITE SERVICES CORPORATION LTD, and the categories of data subject to which that personal data relates;
      • Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
      • Details of how long personal data will be retained by ELITE SERVICES CORPORATION LTD (please refer to ELITE SERVICES CORPORATION LTD’s Data Retention Policy); and
      • Detailed descriptions of all technical and organisational measures taken by ELITE SERVICES CORPORATION LTD to ensure the security of personal data.

11. Data Protection Impact Assessments
    • ELITE SERVICES CORPORATION LTD shall carry out Data Protection Impact Assessments for any new projects and/or new uses of personal data which involve the use of new technologies and the processing involved is likely to result in a high risk to the rights and freedoms of data subjects under the GDPR.
    • Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:
      • The type(s) of personal data that will be collected, held, and processed;
      • The purpose(s) for which personal data is to be used;
      • ELITE SERVICES CORPORATION LTD’s objectives;
      • How personal data is to be used;
      • The parties (internal and/or external) who are to be consulted;
      • The necessity and proportionality of the data processing concerning the purpose(s) for which it is being processed;
      • Risks posed to data subjects;
      • Risks posed both within and to ELITE SERVICES CORPORATION LTD; and
      • Proposed measures to minimise and handle identified risks.

12. Keeping Data Subjects Informed
    • ELITE SERVICES CORPORATION LTD shall provide the information set out in Part 12.2 to every data subject:
      • Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection; and
      • Where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:
        1. if the personal data is used to communicate with the data subject when the first communication is made; or
        2. if the personal data is to be transferred to another party before that transfer is made; or
        3. as soon as reasonably possible and in any event not more than one month after the personal data is obtained.
      • The following information shall be provided:
        • Details of ELITE SERVICES CORPORATION LTD including, but not limited to, the identity of its Data Protection Officer;
        • The purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 21 of this Policy) and the legal basis justifying that collection and processing;
        • Where applicable, the legitimate interests upon which ELITE SERVICES CORPORATION LTD is justifying its collection and processing of the personal data;
        • Where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;
        • Where the personal data is to be transferred to one or more third parties, details of those parties;
        • Where the personal data is to be transferred to a third party that is located outside of the European Economic Area (the “EEA”), details of that transfer, including but not limited to the safeguards in place (see Part 28 of this Policy for further details);
        • Details of data retention;
        • Details of the data subject’s rights under the GDPR;
        • Details of the data subject’s right to withdraw their consent to ELITE SERVICES CORPORATION LTD’s processing of their personal data at any time;
        • Details of the data subject’s right to complain to the Information Commissioner’s Office (the “supervisory authority” under the GDPR);
        • Where applicable, details of any legal or contractual requirement or obligation necessitating the collection and processing of the personal data and details of any consequences of failing to provide it; and
        • Details of any automated decision-making or profiling that will take place using the personal data, including information on how decisions will be made, the significance of those decisions, and any consequences.

13. Data Subject Access
    • Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data that ELITE SERVICES CORPORATION LTD holds about them, what it is doing with that personal data, and why.
    • Data subjects wishing to make a SAR may do so in writing, using ELITE SERVICES CORPORATION LTD’s Subject Access Request Form, or other written communication. SARs should be addressed to ELITE SERVICES CORPORATION LTD’s Data Protection Officer at the business registered address.
    • Responses to SARs shall normally be made within one month of receipt, however, this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.
    • All SARs received shall be handled by ELITE SERVICES CORPORATION LTD’s Data Protection Officer.
    • ELITE SERVICES CORPORATION LTD does not charge a fee for the handling of normal SARs. ELITE SERVICES CORPORATION LTD reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.
14. Rectification of Personal Data
    • Data subjects have the right to require ELITE SERVICES CORPORATION LTD to rectify any of their personal data that is inaccurate or incomplete.
    • ELITE SERVICES CORPORATION LTD shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing ELITE SERVICES CORPORATION LTD of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
    • In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

15. Erasure of Personal Data
    • Data subjects have the right to request that ELITE SERVICES CORPORATION LTD erase the personal data it holds about them in the following circumstances:
      • It is no longer necessary for ELITE SERVICES CORPORATION LTD to hold that personal data concerning the purpose(s) for which it was originally collected or processed;
      • The data subject wishes to withdraw their consent to ELITE SERVICES CORPORATION LTD holding and processing their personal data;
      • The data subject objects to ELITE SERVICES CORPORATION LTD holding and processing their personal data (and there is no overriding legitimate interest to allow ELITE SERVICES CORPORATION LTD to continue doing so) (see Part 18 of this Policy for further details concerning the right to object);
      • The personal data has been processed unlawfully;
      • The personal data needs to be erased in order for ELITE SERVICES CORPORATION LTD to comply with a particular legal obligation.
      • The personal data is being held and processed for the purpose of providing information only to fulfil day-to-day business activities.
    • Unless ELITE SERVICES CORPORATION LTD has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.
    • In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

16. Restriction of Personal Data Processing
    • Data subjects may request that ELITE SERVICES CORPORATION LTD ceases processing the personal data it holds about them. If a data subject makes such a request, ELITE SERVICES CORPORATION LTD shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.
    • In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).
17. Data Portability
    • ELITE SERVICES CORPORATION LTD processes personal data using automated means.
    • Where data subjects have given their consent to ELITE SERVICES CORPORATION LTD to process their personal data in such a manner, or the processing is otherwise required for the performance of a contract between ELITE SERVICES CORPORATION LTD and the data subject, data subjects have the right, under the GDPR, to receive a copy of their personal data and to use it for other purposes (namely transmitting it to other data controllers).
    • To facilitate the right of data portability, ELITE SERVICES CORPORATION LTD shall make available all applicable personal data to data subjects in the following formats:’,
      • Structured and
      • Machine-readable
    • Where technically feasible, if requested by a data subject, personal data shall be sent directly to the required data controller.
    • All requests for copies of personal data shall be complied with within one month of the data subject’s request. The period can be extended by up to two months in the case of complex or numerous requests. If such additional time is required, the data subject shall be informed.
18. Objections to Personal Data Processing
    • Data subjects have the right to object to ELITE SERVICES CORPORATION LTD processing their personal data based on legitimate interests, direct marketing (including profiling), [and processing for scientific and/or historical research and statistics purposes.
    • Where a data subject objects to ELITE SERVICES CORPORATION LTD processing their personal data based on its legitimate interests, ELITE SERVICES CORPORATION LTD shall cease such processing immediately, unless it can be demonstrated that ELITE SERVICES CORPORATION LTD’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.
    • Where a data subject objects to ELITE SERVICES CORPORATION LTD processing their personal data for direct marketing purposes, ELITE SERVICES CORPORATION LTD shall cease such processing immediately.
    • [Where a data subject objects to ELITE SERVICES CORPORATION LTD processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the GDPR, “demonstrate grounds relating to his or her particular situation”. ELITE SERVICES CORPORATION LTD is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.

19. Automated Decision-Making
    • ELITE SERVICES CORPORATION LTD uses personal data in automated decision-making processes.
    • Where such decisions have a legal (or similarly significant effect) on data subjects, those data subjects have the right to challenge to such decisions under the GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from ELITE SERVICES CORPORATION LTD.
    • The right described in Part 19.2 does not apply in the following circumstances:
      • The decision is necessary for the entry into or performance of, a contract between ELITE SERVICES CORPORATION LTD and the data subject;
      • The decision is authorised by law; or
      • The data subject has given their explicit consent.

20. Profiling
    • ELITE SERVICES CORPORATION LTD may use personal data for profiling purposes. Keeping a record of traffic violations to monitor the driving habits of individuals over time to identify repeat offenders (which may have an impact on the sanction)7; and
    • Considering an individual’s credit score/DBS checks before granting contracts of employment
    • When personal data is used for profiling purposes, the following shall apply:
      • Clear information explaining the profiling shall be provided to data subjects, including the significance and likely consequences of the profiling;
      • Appropriate mathematical or statistical procedures shall be used;
      • Technical and organisational measures shall be implemented to minimise the risk of errors. If errors occur, such measures must enable them to be easily corrected; and
      • All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling (see Parts 22 to 26 of this Policy for more details on data security).

21. Personal Data Collected, Held, and Processed

The following personal data is collected, held, and processed by ELITE SERVICES CORPORATION LTD (for details of data retention, please refer to ELITE SERVICES CORPORATION LTD’s Data Retention Policy):

The following personal data may be collected, held, and processed by ELITE SERVICES CORPORATION LTD:

Name and address, personal phone numbers and email address, work history in the form of a CV, proof of right to work in the UK e.g. passport, birth certificate, ID card, bank details (in the event that you temp for us on our payroll), National insurance Number, Educational professional certificates licenses.

Data Security - Transferring Personal Data and Communications

ELITE SERVICES CORPORATION LTD shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

• All emails containing personal data must be encrypted
• All emails containing personal data must be marked “confidential”;
• Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
• Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
• Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;
• Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient and
• All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”.

22. Data Security - Storage

ELITE SERVICES CORPORATION LTD shall ensure that the following measures are taken with respect to the storage of personal data:

• All electronic copies of personal data should be stored securely using passwords and data encryption;
• All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;
• No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to ELITE SERVICES CORPORATION LTD or otherwise without the formal written approval of employees and contractors, clients and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary; and
• No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of ELITE SERVICES CORPORATION LTD where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the GDPR (which may include demonstrating to ELITE SERVICES CORPORATION LTD that all suitable technical and organisational measures have been taken).

23. Data Security - Disposal

When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to ELITE SERVICES CORPORATION LTD’s Data Retention Policy.

24. Data Security - Use of Personal Data

ELITE SERVICES CORPORATION LTD shall ensure that the following measures are taken with respect to the use of personal data:

• No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of ELITE SERVICES CORPORATION LTD requires access to any personal data that they do not already have access to, such access should be formally requested from HR;
• No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of ELITE SERVICES CORPORATION LTD or not, without the authorisation of the HR manager;
• Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors, or other parties at any time;
• If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it; and

25. Data Security - IT Security

ELITE SERVICES CORPORATION LTD shall ensure that the following measures are taken with respect to IT and information security:

• All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols.
• Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of ELITE SERVICES CORPORATION LTD, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
• All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. ELITE SERVICES CORPORATION LTD’s IT staff shall be responsible for installing any and all security-related updates not more than a reasonable period after the updates are made available by the publisher or manufacturer as soon as reasonably and practically possible unless there are valid technical reasons not to do so; and
• No software may be installed on any Company-owned computer or device without the prior approval of the Managing director.

26. Organisational Measures

ELITE SERVICES CORPORATION LTD shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

• All employees, agents, contractors, or other parties working on behalf of ELITE SERVICES CORPORATION LTD shall be made fully aware of both their individual responsibilities and ELITE SERVICES CORPORATION LTD’s responsibilities under the GDPR and under this Policy, and shall be provided with a copy of this Policy;
• Only employees, agents, sub-contractors, or other parties working on behalf of ELITE SERVICES CORPORATION LTD that need access to, and use, personal data in order to carry out their assigned duties correctly shall have access to personal data held by ELITE SERVICES CORPORATION LTD;
• All employees, agents, contractors, or other parties working on behalf of ELITE SERVICES CORPORATION LTD handling personal data will be appropriately trained to do so;
• All employees, agents, contractors, or other parties working on behalf of ELITE SERVICES CORPORATION LTD handling personal data will be appropriately supervised;
• All employees, agents, contractors, or other parties working on behalf of ELITE SERVICES CORPORATION LTD handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;
• Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
• All personal data held by ELITE SERVICES CORPORATION LTD shall be reviewed periodically, as set out in ELITE SERVICES CORPORATION LTD’s Data Retention Policy;
• The performance of those employees, agents, contractors, or other parties working on behalf of ELITE SERVICES CORPORATION LTD handling personal data shall be regularly evaluated and reviewed;
• All employees, agents, contractors, or other parties working on behalf of ELITE SERVICES CORPORATION LTD handling personal data will be bound to do so in accordance with the principles of the GDPR and this Policy by contract;
• All agents, contractors, or other parties working on behalf of ELITE SERVICES CORPORATION LTD handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of ELITE SERVICES CORPORATION LTD arising out of this Policy and the GDPR; and
• Where any agent, contractor or other party working on behalf of ELITE SERVICES CORPORATION LTD handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless ELITE SERVICES CORPORATION LTD against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

27. Transferring Personal Data to a Country Outside the EEA
    • ELITE SERVICES CORPORATION LTD may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the EEA.
    • The transfer of personal data to a country outside of the EEA shall take place only if one or more of the following applies:
      • The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that the European Commission has determined ensures an adequate level of protection for personal data;
      • The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses adopted by the European Commission; compliance with an approved code of conduct approved by a supervisory authority (e.g. the Information Commissioner’s Office); certification under an approved certification mechanism (as provided for in the GDPR); contractual clauses agreed and authorised by the competent supervisory authority; or provisions inserted into administrative arrangements between public authorities or bodies authorised by the competent supervisory authority;
      • The transfer is made with the informed consent of the relevant data subject(s);
      • The transfer is necessary for the performance of a contract between the data subject and ELITE SERVICES CORPORATION LTD (or for pre-contractual steps taken at the request of the data subject);
      • The transfer is necessary for important public interest reasons;
      • The transfer is necessary for the conduct of legal claims;
      • The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; or
      • The transfer is made from a register that, under UK or EU law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

28. Data Breach Notification
    • All personal data breaches must be reported immediately to ELITE SERVICES CORPORATION LTD’s Data Protection Officer.
    • If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.
    • In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 29.2) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
    • Data breach notifications shall include the following information:
      • The categories and approximate number of data subjects concerned;
      • The categories and approximate number of personal data records concerned;
      • The name and contact details of ELITE SERVICES CORPORATION LTD’s data protection officer (or other contact point where more information can be obtained);
      • The likely consequences of the breach;
      • Details of the measures taken, or proposed to be taken, by ELITE SERVICES CORPORATION LTD to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

29. Implementation of Policy

This Policy shall be deemed effective as of ----/----/----. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

This Policy has been approved and authorised by:

Approved

Managing Director      

ELITE SERVICES CORPORATION LTD

This policy is reviewed on 01/12/2023