This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the “Data Subject”) who is not already in the public domain.
The Personal Data Protection Law (PDPL) seeks to protect and enhance the rights of data subjects. In the United Arab Emirates (U.A.E.), the PDPL serves as the primary legislation governing the protection of personal data. These regulations cover the safeguarding of personal data, protection against the unlawful processing of personal data, and the unrestricted movement of personal data within the country. It should be noted that PDPL does not apply to information already in the public domain, such as publicly available data from official sources.
Lead Element International is pleased to provide the following PDPL information:
Who we are
Lead Element International is a U.A.E. based Security Personnel Company
Lead Element International uses the information collected from you to provide services and marketing information that Lead Element International believes may be of interest to you and your business. In having made your initial contact with Lead Element International, you consent to Lead Element International maintaining a marketing dialogue with you until either you opt out (which you can do at any stage) or we decide to discontinue promoting our services. Lead Element International also acts on behalf of its clients in the capacity of data processor. When working exclusively as a data processor, Lead Element International will be acting on the instruction of its client and will aim to ensure that the client is fully GDPR compliant.
Some personal data may be collected about you from forms and surveys that you complete; from records of our correspondence and phone calls; and from details of your visits to our website, including but not limited to personally identifying information such as Internet Protocol (IP) addresses. Lead Element International may from time to time use such information to identify its visitors. Lead Element International may also collect statistics about the behaviour of visitors to its website along with transaction information collected in the process of performing its business.
Any information Lead Element International holds about you and your business encompasses all the details we hold about you and any sales transactions, including any third-party information, we have obtained about you from public sources and our own suppliers, such as credit referencing agencies.
Lead Element International will only collect the information needed so that it can provide you with its services. Lead Element International does not sell or broker your data, although coincidentally there may be times when your information could be contained in data that Lead Element International has purchased from a third-party list broker, on behalf of a client.
If you visit any site/location that Lead Element Security controls, we may collect data via BWVC (Body Worn Video Camera). This data is controlled and processed by Lead Element Security only and can only be accessed in case of a request (whether it be by the subject or an official agency). All data collected via BWVC can only be accessed via the data controller and it is recorded for each step taken. If you would like to request data that we hold on you, please email firstname.lastname@example.org with a subject access request form and we will do our best to accommodate in line with the ICO’s guidelines.
To download a subject access request form template, click here.
Who we share your personal information with
Lead Element International will not pass on your personal data to third parties unless: it is a requirement of the service or product you have with us, where this will be detailed within the contract, if it is a prerequisite to the service or product you intend to have with us, you will be notified beforehand, we wish to undertake marketing to you under our legitimate interests, or it is a legal requirement to do so.
- Network service providers who provide the service agreed in your contract
- Other service providers if purchased through us, e.g. insurance companies
- Companies we have a joint venture or agreement to co-operate with
- Companies we have contracts with, to provide you with the services agreed in your contract, e.g. device repair centres
- If you use direct debits, we will share your data with the Direct Debit scheme
- Debt collection agencies or other debt recovery organisations
- Law enforcement agencies, regulatory organisations, courts or other public authorities if we have to, or are authorised to do so by law
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets as part of the process of evaluation and to ensure continuity of service
Lead Element International may from time to time share your details with third party analytical resources for the purposes of better understanding customer behaviour and performance, website performance, improved ad relevance and any other analytical process to give Lead Element International a better understanding of how to develop its offering to its customers. These third parties will be employed solely for the purpose of the aforementioned analytical purposes, and as such Lead Element International will ensure that the third party is contractually obliged to use the data only for the analytical purposes set out in the agreement between Lead Element International and the third party, and Lead Element International will also ensure that the third party is contractually required to maintain a level of security around the shared data, at least as safe as Lead Element International itself employs. Failure on the part of the third party to meet its contractual obligations will result in Lead Element International recovering the data, and taking all reasonable actions to ensure the third party no longer has access to the shared data. Any third party cookies used on Lead Element International will adhere to the same standards as first party cookies and not collect any personally identifiable information.</
Legal basis for processing any personal data
To meet Lead Element International's contractual obligations to clients and to conform to relevant legal obligations they have.
Legitimate interests pursued by Lead Element International and/or its clients
To promote the services offered by Lead Element International and/or to market the services and/or products offered by Lead Element International's existing clients.
Through agreeing to this privacy notice you are consenting to Lead Element International processing your personal data for the purposes outlined. You can withdraw consent at any time by emailing email@example.com; by phoning +44 (0)207 126 7071; or by writing to us. See last section for full contact details.
Lead Element International may, on occasion, pass your Personal Information to third parties exclusively to process work on its behalf. Lead Element International requires these parties to agree to process this information based on our instructions and requirements consistent with this Privacy Notice and GDPR. Lead Element International does not broker or pass on information gained from your engagement without your consent. However, Lead Element International may disclose your Personal Information to meet legal obligations, regulations, or valid governmental requests. Lead Element International may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions, to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property, or safety of Lead Element International, its clients and/or the wider community.
Lead Element International will process personal data during the duration of any contract and will continue to store only the personal data needed for seven years after the contract has expired to meet any legal obligations. After seven years any personal data not needed will be deleted.
Data is held on multiple servers within the United Arab Emirates (U.A.E.). Lead Element International does not store personal data outside the U.A.E.
Although Lead Element International does not store personal data outside of the United Arab Emirates (U.A.E.), in certain circumstances we may need to transfer personal data outside of the U.A.E. in order to provide our services (e.g. when processing transactions for international numbers). In such cases, Lead Element International is committed to ensuring that third-party data processors, who may themselves store personal data outside of the U.A.E., adhere to the highest possible level of data privacy. We will, wherever practically possible, impose legally binding obligations on said third parties. This may include, but is not limited to, relying on U.A.E. adequacy decisions and/or relevant data privacy regulations, and/or enforcing standard contractual provisions.
Your rights as a data subject
At any point whilst Lead Element International is in possession of or processing your personal data, all data subjects have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply, you have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
- In the event that Lead Element International refuses your request under rights of access, we shall provide you with a reason, which you have the right to challenge legally. Lead Element International can, at your request, confirm what information it holds about you and how it is processed.
You can request the following information:
- Identity and the contact details of the person or organisation (Lead Element International) that has determined how and why to process your data.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Lead Element International or a third party such as one of its clients, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority (ICO).
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it was not collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
To access details of what personal data is held, identification will be required. Lead Element International will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence; passport; birth certificate; and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Lead Element International is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to firstname.lastname@example.org or by phoning +44 (0)207 126 7071 or by writing to us at the address further below.
In the event that you wish to make a complaint about how your personal data is being processed by Lead Element International or its partners, you have the right to complain to Lead Element International directors. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
Lead Element International, attention of the Operations Director
Business Center 1, M Floor, The Meydan Hotel, Nad Al Sheba, Dubai, U.A.E
Telephone +44 (0)207 126 7071 or email email@example.com
Modern slavery Policy Statement
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. This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Lead Element Security Group 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. Lead Element Security Group 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.
Lead Element Security Group Ltd operates a supplier policy and maintains a preferred supplier list. We conduct due diligence on all suppliers before allowing them to become a preferred supplier. This due diligence includes an online search to ensure that organisation has never been convicted of offenses relating to modern slavery (and on-site audits which include a review of working conditions). All Our suppliers are required to confirm that no part of their business operations contradicts this policy.
In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
- They have taken steps to eradicate modern slavery within their business.
- They hold their own suppliers to account over modern slavery.
- (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate).
- (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations.
- We may terminate the contract at any time should any instances of modern slavery come to light.
We regularly conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.
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.