How we handle your information

1.Who we are

Elite Executive Career Solutions is a trading name of New Elite Holdings (Pty) Ltd, a private company registered in the Republic of South Africa. Our company registration details are available to verified clients on request. In this policy, “we”, “us” and “our” mean that company, and “you” means the person whose information we hold.

We are the responsible party for your personal information under the Protection of Personal Information Act 4 of 2013 (POPIA), and the controller for the purposes of the UK and EU General Data Protection Regulation (GDPR) where those apply to you. For all privacy matters, write to us at [email protected].

2.What this policy covers

This policy covers personal information we collect through elite-cv.com, through our chat and WhatsApp lines, by email, and in the course of our work, across all three of our divisions:

• Executive Solutions, the advisory and document services we provide to senior leaders
• Corporate Solutions, the services we provide to organisations, including tender documentation, workforce transition support and website development
• Smart CV, the self-service platform for rising professionals

Cookies and similar technologies are covered in our Cookie Policy. How to exercise your rights, and our PAIA manual, are on the Data Protection and POPIA page.

3.The information we collect

What we hold depends on how you deal with us. Most of it comes from you directly. Some of it comes from someone else, and where that happens we say who below.

Information we receive from someone else

If an organisation engages us to support its people, for example through workforce transition support or a tender team, that organisation may give us your name, contact details, role and career information so that we can begin. If someone refers you to us, they may give us your name and contact details. In both cases we use the information only for the purpose it was given, and we tell you about this policy when we first contact you.

4.Special personal information

POPIA treats some information as especially sensitive: information about your race or ethnic origin, religious or philosophical beliefs, trade union membership, political persuasion, health or sex life, biometric information, and criminal behaviour. The GDPR has a similar list.

We do not ask for any of it. A well-positioned executive document rarely needs it. CVs and career histories sometimes contain it anyway, for example a photograph, a board seat at a religious or political body, or an equity programme you led. Where you choose to include information of this kind, we process it only because you have consented to it being used to prepare your documents, and you can withdraw that consent at any time. We will tell you if we think something you have included would be better left out.

An identity or passport number is not special personal information, but it can be misused if it falls into the wrong hands. We advise against including it unless your target market expects it, and we handle it with the same care as special information when you do.

5.Why we use it, and the lawful basis for doing so

We use your information only for the purposes below. POPIA requires a lawful justification for each one, and so does the GDPR where it applies. The table shows both.

We will not use your information for a new purpose that is unrelated to the one it was collected for without telling you first and, where the law requires it, asking for your consent.

6.Whether you have to give it to us

Giving us your information is voluntary. Some of it is needed for us to do the work: without your contact details we cannot reach you, without payment details we cannot take an order, and without a completed intake questionnaire we cannot write your documents. If you choose not to provide what a service needs, we will not be able to provide that service. Everything else, including photographs and personal details, is your choice.

No law requires you to give us personal information, although tax and company law require us to keep records of transactions once you have made one.

7.Who we share it with

We do not sell your information, and we never disclose your identity or your documents to anyone for their own purposes. Where we refer to a client publicly, for example in a testimonial, it is by role, sector and country only.

We use service providers to run the business. They process information on our instructions, and we share only what each one needs:

We may also disclose information where the law requires it, for example to comply with a court order or a lawful request from a regulator, or to protect our legal rights. If the business or part of it is ever sold or restructured, client information may pass to the new owner on the same terms as this policy, and we would tell you first.

We require everyone who works on client documents, whether employed by us or contracted to us, to keep them confidential.

8.Transfers outside South Africa

Several of the providers above process information outside South Africa. POPIA allows this only on specific grounds. We rely on one or more of the following for each transfer:

• the provider is subject to a law, binding corporate rules or a binding agreement that gives protection substantially similar to POPIA
• the transfer is necessary to perform our contract with you, for example taking a PayPal payment or replying on WhatsApp
• you have consented, for example by accepting analytics and advertising cookies

Where the GDPR applies, transfers out of the UK or European Economic Area rely on adequacy decisions or on standard contractual clauses in the provider’s terms. You can ask us for more detail on any particular transfer.

9.How long we keep it

We keep personal information only as long as we need it, and then delete or de-identify it.

You do not have to wait five years. Ask us to delete your information and we will do so within 72 hours of confirming the request, except for the records tax and company law require us to keep. Those we retain, securely, only for as long as that law requires.

10.How we protect it

We take reasonable technical and organisational measures to keep your information secure and to prevent its loss, misuse or unauthorised access. These include an encrypted connection across the whole website, bot protection on forms, access to client files limited to the people working on your engagement, and payment handled entirely by specialist payment providers. Our writers never deal with clients directly, which keeps the number of people who see your correspondence small.

No system is perfectly secure. If we become aware that your personal information has been accessed or acquired by someone without authority, we will notify you and the Information Regulator as soon as reasonably possible, as POPIA requires, and tell you what we are doing about it.

11.Marketing

We send marketing only in the ways the law allows, and every message tells you who it is from and how to stop it.

• If you are a client, we may send you our newsletter and news of services similar to ones you have bought. You can opt out when you first give us your details and in every message after that.
• If you are not a client, we will contact you for marketing only if you have given us your consent, for example by subscribing. We will ask for that consent once, and if you decline we will not ask again.
• Advertising measurement through Google and LinkedIn happens only if you accept marketing cookies.

To stop marketing, use the unsubscribe link in any email, or write to [email protected]. Opting out costs nothing and does not affect any service you have bought.

12.Cookies and similar technologies

We use cookies and browser storage to run the site, to remember your choices, and, only with your consent, for chat, analytics and advertising measurement. Our Cookie Policy lists every one of them, and you can change your choice at any time through the cookie settings link on every page.

13.Automated decisions

We do not make decisions about you that have legal or similarly significant effects based solely on automated processing. The ATS scan in Smart CV produces an automated assessment of your document for your own use. It is not a decision about you, and nobody else sees it.

14.Your rights

Under POPIA you have the right to:

• know whether we hold personal information about you, and ask for a copy of it
• ask us to correct information that is inaccurate, out of date or incomplete, or to delete information we are no longer entitled to keep
• object to our processing your information, including for direct marketing
• not be subject to a decision based solely on automated processing that affects you substantially
• withdraw any consent you have given, without affecting processing that took place before you withdrew it
• complain to the Information Regulator

Correcting, deleting and objecting cost nothing. The Data Protection and POPIA page explains exactly how to make each request, how we verify that it is you, and how quickly we respond.

15.If you are in the United Kingdom or the European Union

Where the UK or EU GDPR applies to you, you have the rights above and, in addition, the right to ask us to restrict how we use your information while a concern is resolved, and the right to receive information you gave us in a structured, commonly used, machine-readable format, or to have it sent to someone else. The lawful bases we rely on are set out under Why we use it.

If you have a concern, please raise it with us first at [email protected]. We will acknowledge your complaint within 30 days and tell you what we are doing about it. You also have the right to complain to a supervisory authority: in the United Kingdom, the Information Commissioner’s Office, and in the European Union, the data protection authority in the country where you live or work.

16.Children

Our services are intended for adults. We do not knowingly collect personal information from anyone under 18. If you are under 18, a parent or guardian must place any order and consent to our processing your information. If we learn we have collected a child’s information without that consent, we will delete it.

17.Complaints

If you are unhappy with how we have handled your information, please tell us first so we can put it right. Write to [email protected] with the subject line “Privacy”. You are also entitled to complain directly to the Information Regulator of South Africa, whose details are on our Data Protection and POPIA page.

18.Changes to this policy

We will update this policy when our practices or the law change. The date at the top of the page shows when it last changed. If a change materially affects how we use information we already hold about you, we will tell you directly before it takes effect.

19.Contact us