Welcome to Elgin White’s Privacy Policy. Please read this policy carefully before using Elgin White’s Services.
Elgin White Limited (“Elgin White“, “our”, “us” or “we”), a company registered in England at 4 Cedar Park, Cobham Road Ferndown Industrial Estate, Wimborne, Dorset, United Kingdom, BH21 7SF under Company Number 05887418 and ICO registration number Z9797426, is the controller and responsible for your personal data.
Our consultancy services provide financial institutions with advice, support, and resourcing when undertaking business change management and technology transformation projects (the “Services”).
Protecting data, privacy, and personal information is very important to us. This policy sets out the basis on which we process personal data (also referred to as “personal information” or “information“) in connection with our Services, and when you use or visit our website (regardless of where you visit it from), sign up to our newsletter, or contact us, for instance, to make an inquiry or to request a call. The policy will also tell you about your privacy rights and how the law protects you.
This website is not intended for children, and we do not knowingly collect data relating to children.
Please ensure you read this privacy policy carefully to understand the types of information we collect, how we use that information, the circumstances under which we will share it with third parties, and your rights in relation to personal data about you.
Please read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager at privacy@elginwhite.com.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We keep our privacy policy under regular review. This version was last updated on 30 September 2023. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins, and applications, for example to Twitter, LinkedIn, YouTube, Vimeo, and others. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:
You will be asked to provide us with some basic information so that we can set you up with an account and so that we can manage this account. We will also ask you to provide some contact information so that we can reach out to you if that is necessary in relation to our Services. We will use this information to respond to any queries you may have in relation to our Services. This information typically includes your name, corporate email address, and phone number. We need this information in order to provide our Services to the organization you represent (i.e., our Clients). Although much of this data is collected through direct interactions with you when you give us information by filling in forms or corresponding with us by phone, email, online, or otherwise, please note that sometimes the same information may be passed onto us directly from the organization you represent.
We may approach you offline or online (for example on social media) and inquire whether the organization you represent is interested in our Services. We will use whatever information you have decided to publish on your, say, LinkedIn profile, to do that. We will also use whatever information you have decided to share with us offline by way of, say, exchanging business cards, to do that.
We may also approach you via other online channels, such as email, if we believe our Services or any promotional materials about our Services may be of interest to the organization you represent (i.e., our Clients). We will use your name and email address to do that.
We will contact you if you fill in any of the web forms on our website. When we do that, we will use the contact details you have decided to provide in the relevant form.
We will send you our e-newsletter if you subscribe to it. We will use your name and email address to do that.
Where you represent one of our former, current, or future Suppliers, we will ask you to provide us with some basic information so that we can receive and pay for the services your organization provides. Such information typically includes your name, corporate email address, and phone number.
We may collect and use marketing and communications data, including your preferences in receiving marketing from us and our third parties and your communication preferences.
When you visit our website certain technical information about the device you use to access our website that may identify you will be generated by cookies, web-beacons, and other similar tracking technologies. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our Cookie Policy for the technical details about this type of data processing.
Please use the cookies banner on our website to exercise your choice regarding accepting or rejecting cookies.
We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data (for example, information about how you use our website, resources, and services) to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not generally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
We may also collect data from third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
(a) analytics providers such as Google based outside the UK
(b) advertising networks based inside or outside the UK; and
(c) search information providers based inside or outside the UK
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note: we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data, where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer | (a) Identity (b) Contact |
Performance of a contract with you |
| To process and deliver your order including: (a) Manage payments, fees, and charges (b) Collect and recover money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing/ Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing/ Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing/ Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We will treat your information as confidential information and treat it in accordance with the law, and so shall our Suppliers and all third parties we provide this information to. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We use various technological solutions providers in order to deliver, manage, improve, and promote our Services. Our Suppliers are prohibited from using personal data for any purpose other than the delivery of their services to us. Nevertheless, depending on their type, our Suppliers may have access to your information. These providers include our cloud storage providers, customer relationship management systems providers, email services providers, social media companies, analytics providers, and others to assist us in promoting, delivering, managing, and improving our Services and our website. In addition, we may also disclose your personal information to third parties in the following circumstances:
| Purpose of disclosure | Justification |
| if we buy any business or assets, we may disclose your personal information to the prospective seller of such business or assets | legitimate interests (to enable the acquired business to offer services to our Clients) |
| if Elgin White or substantially all of its assets are acquired by a third party, personal information about our Clients’ and Suppliers’ representatives will be one of the transferred assets | legitimate interests (to allow the prospective buyers to provide you the Services) |
| if we need to protect the rights, property, or safety of Elgin White, our Clients, or others, we may disclose your personal information to third parties, such as professional advisors and official authorities | legitimate interests (to enforce our rights) |
|
we may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless doing so would prejudice the prevention or detection of a crime. |
legal obligation |
Elgin White operates an information security management program that aligns with the ISO 27001 standard on information security management and has certified our compliance with this standard.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
Our security program applies to all information we hold and not only to personal data. All of our key Suppliers employ industry-leading standards in information security and contractually guarantee to keep personal information secure.
Where necessary we have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Your personal information will be stored electronically on computer systems located in the United Kingdom and managed by our Suppliers. In certain limited circumstances, your personal information may be accessed by staff, stored with, or transferred by our Suppliers in, a destination outside the United Kingdom (“UK”) or the European Economic Area (“EEA”) in which data protection laws may be of a lower standard than in the UK or the EEA.
Regardless of location, we will impose data protection safeguards similar to those that we deploy inside the UK and the EEA. Where required by applicable law, we will transfer your personal information subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient. Please contact us if you would like further details of the specific safeguards applied to the export of your personal data.
We will hold the above information for as long as is necessary in order to conduct the processing detailed above, deal with any specific issues that may be raised, or otherwise as is required by law or any relevant regulatory body, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
Once we end the commercial relationship with the organization you represent, some personal data may need to be retained to ensure Elgin White can comply with applicable laws and internal compliance procedures. Such personal data may be retained for up to 6 years.
We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the personal risk or harm from unauthorized use or disclosure, the purpose for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
Under the General Data Protection Regulation (EU) 2016/679 (and under the UK GDPR), under certain circumstances, you have various rights in relation to your personal data. All these rights can be exercised by contacting us at the email address specified below.
You have the right to:
| be informed (of the processing); | access (such information); | rectification (of inaccurate information); |
| Erasure (of such information); | restrict processing (in certain cases); | object to profiling; |
| data portability (in certain cases); | complain to the Information Commissioner’s Office; | withdraw consent (if we have collected your personal information on this basis). |
Detailed information on the full content of your rights (and any conditions that may apply) is provided by the United Kingdom’s Information Commissioner’s Office and is available on their website: https://ico.org.uk/your-data-matters/.
Asking us to stop processing your personal data or deleting your personal data will likely mean that you and/or the organization you represent will no longer be able to use Elgin White’s Services, or at least those aspects of the Services that require the processing of the types of personal data you have asked us to delete. If you represent a Supplier, asking us to stop processing your personal data or deleting your personal data will likely mean that we will no longer be able to use the third-party services that your organization provides to us.
While we will not sell your personal data (or any other data you provide us with) to third parties, we reserve the right to share any data that has been anonymized. You acknowledge and accept that we own all right, title and interest in and to any derived data or aggregated and/or anonymized data collected or created by us.
Any changes we make to our Privacy Policy in the future will be posted on this page, and where appropriate, notified to you by email. We therefore encourage you to review it from time to time to stay informed of how we are processing your information.
Last update: 30 September, 2023
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Elgin White is
ISO 27001:2022 certified
Based in Los Angeles, California, Jeremy founded InvestTech Systems Consulting LLC in 1990. As President and Director the Enterprise Data Management and Architecture Practice for more than 25 years he managed over 50 large investment technology, strategy, and implementation projects for many of the largest global investment management firms. Following the acquisition of his firm by Accenture in 2017, Jeremy remained as Managing Director, Asset Management Lead.
Jeremy joined Elgin White in 2022 to lead the firm’s launch into North America. He is recognized throughout the North America asset management community as a thought leader and innovation architect in the design of enterprise data, analytics, and reporting platforms. His deep knowledge, broad buy-side network, and extensive experience deploying business-outcome-focused technology solutions successfully has accelerated the growth of Elgin White in North America.
Stan joined Elgin White in 2020 following an impressive 30-year career working predominantly for world-class buy-side financial services firms in North America and Europe. He is a renowned buy-side technology leader with a reputation for designing and delivering large-scale transformation initiatives at scale and pace. Currently, Stan is especially active leading infrastructure (cloud and managed services) transformation projects.
His most recent roles prior to Elgin White include Chief Information Officer (EMEA) at State Street and various senior positions during his eight-year tenure at Northern Trust Corporation, including Head of IT & EMEA/Global Director of Fund Administration Technology, Global Director of Asset Management Technology, and Director of Trade Execution Technologies. Stan has also held senior Operational and Technology roles at Nuveen Investments and BNY Mellon.
Throughout his career Stan has been a strategic client or partner of every major front-to-back office technology vendor including SimCorp and Charles River Development.
Erik founded Elgin White’s consultancy practice in 2019, which transitioned the firm into a full-service buy-side consultancy and resourcing business. He is an experienced front-to-back business transformation professional and has held several senior management positions during his more than 30-year career in the UK and his native Netherlands, as well as Asia Pacific.
Previous roles include Head of Professional Services at SimCorp, Director at PwC UK, and Managing Director for Wealth & Asset Management Services at Accenture UK & Ireland.
