Elite Model Management London Ltd (“Company”, “we” or “us”) is committed to protecting privacy and security when processing your personal data. It is important that you read and keep in mind why and how we are using your data and what your rights are under the relevant data protection legislation. In the following ‘data subject’ refers to the person to whom the personal data is concerned with.
Elite Model Management London Ltd, Burleigh House, 4 Floor, 355 Strand London WC2R 0HS, United Kingdom, part of the Elite World Group (EWG), determines the purposes and means of the processing of personal data.
What is the purpose of processing?
This Privacy Notice relates to our scouting activities aimed at finding new talents for our modelling services.
How we get your personal data and what is the data collected?
- Many potential models have public accounts on social networks in order to promote themselves via videos, stories, reels and posts: we take a look at these publications and where we find a case of possible interest, we take note of the data that can be useful for our services, in the event you have decided to make them publicly available
- In the event we meet you casually on the street or at an event, we will ask for your contact details directly, as well as some pictures of you, and some other data such as age and gender
- If you do a walk-in at our offices and you go through the usual internal process, you share your contact details/pictures/physical measurements, age and gender
- If you voluntarily, by email or regular mail or by any other means of communication, send us your contact details and/or pictures and/or physical measurements or other data about yourself
- If someone you relied on to promote your image as a possible talent, contacts us by regular mail or email or by any other means of communication or physically comes to our offices and provides us with your contact details and/or photos and/or physical measurements or other data about you
In case you fill in a specific form, you can always access to the specific Privacy Notice made available on our resources (website, APP, paper document) or here.
Legal basis for processing
The legal basis is our legitimate interest in finding new potential talent among those who have voluntarily made their data public because they wish to promote themselves.
On the other hand, the legal basis is to take action at the request of the data subjects before entering into a possible contract with us, for those who have communicated their data to us (directly or through their agents) always with the aim of promoting themselves.
Where the data collected as reported above includes sensitive (*) data, it can be treated because the processing relates to personal data which are manifestly made public by the data subject.
(*) data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, data concerning health or data concerning a natural person's sex life or sexual orientation
Data Sharing and personal data transfers outside European Union, United Kingdom and Switzerland
We may have to share your data with other companies of the Group always with the purpose of assessing your potential as model and your data is processed with the support of service providers: such parties are obliged to comply with the relevant data protection legislation. Where such parties process personal data on our behalf, they are contractually obliged to properly protect your personal data and follow our instructions. If required by law, we will share your data with relevant authorities.
If the above-mentioned parties are established outside of the European Union, United Kingdom, and Switzerland, we adopt, according to the specific case, the applicable safeguards provided for by the data protection legislation.
How we store your personal data and for how long?
We store your data, for the above purposes, securely and in compliance with the provisions of the applicable laws that protect confidentiality, integrity, and availability of your personal data. We limit access to your personal data to those employees, agents, contractors and other third parties who have a strict business need to know your data.
Your personal data will be retained for the time strictly necessary for the assessment of your potential as a model: if the assessment procedure doesn’t end up with the establishment of a contractual relationship with you, your personal data will be retained for 3 years from the end of such procedure to allow us to assess your profile for future opportunities.
The data may be retained for a further period if necessary to comply with legal obligations and/or to exercise or defend a right.
When we no longer need to use your personal data, we delete it from our systems or anonymize it so that it no longer identifies you.
What are your privacy rights?
According to the relevant data protection law, you can exercise the above rights on a case-by-case basis, as applicable to the specific processing situation:
- obtain from us the following information: the purposes of the processing; the categories of personal data concerned; the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period. If requested we shall provide a copy of your personal data undergoing processing, in a commonly used electronic form, however your right to obtain a copy shall not adversely affect the rights and freedoms of others
- obtain without undue delay correction of your personal data in case it is incomplete or inaccurate or necessary any integration provided by you
- obtain erasure of your personal data under certain conditions: where the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent on which the processing is based and when there is no other legal ground for the processing; you object to the processing and there are no overriding legitimate grounds for the processing, or you object to the processing for direct marketing communications addressed to you; the personal data have been unlawfully processed; the personal data have to be erased for compliance with a legal obligation to which the Controller is subject; the personal data have been collected in relation to the offer of information society services to minors
- object to the processing when there are no overriding legitimate grounds for the processing, or you object to the processing in case of direct marketing communications addressed to you
- obtain restriction of processing where one of the following applies: you contest the accuracy of the personal data, for a period enabling the Controller to verify such accuracy; the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; the Controller no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; you have objected to processing pending the verification whether the legitimate grounds of the Controller override yours
- obtain the portability of your personal data to another party, this right is applicable when the processing is carried out by automated means and the legal ground for processing is your consent or the contractual relationship with the Controller.
- object to the processing, including profiling, which produces legal effects on you or similarly significantly affect you except when the processing is necessary for entering into, or performance of, a contract between you and the Controller; or is authorised by a law to which the Controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or is based on your explicit consent.
You have the right to lodge a complaint with a supervisory authority, in particular in the State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes the applicable data protection law. For example, in France the reference supervisory authority is the CNIL www.cnil.fr.
For further information on how we process your personal data, your privacy rights and to exercise them, or for any issue related to the processing of your data, contact our Data Protection Officer by sending an email to email@example.com or a regular mail to the Company address reported in the section ‘Controller’.