Our story
ELIAS began as a data governance and Data Protection Officer practice, working with organisations in the UK and internationally in healthcare, sport, media and Business Improvement Districts. Over time our work drew us towards the hardest questions in the field. When is it lawful to identify someone by their face? How do you keep a watchlist fair? What should a self-excluded gambler, or a shopper wrongly flagged, be able to expect?
Those questions are now our main focus. We have spent more than five years in the land-based gambling sector, guided clients through ICO investigations into facial recognition, and helped write the standard the sector can measure itself against. We still offer our wider data protection work, and the facial recognition focus has made it better.
What makes us different
Calm, candid help when something has gone wrong, with counsel on hand.
Independent advice
We judge technology on evidence, not on who makes it. Our recommendations never depend on what you buy. That means we can tell you how to deploy, and also whether you should.
Law and technology, together
Few advisers are fluent in both. We understand the lawful basis and the algorithm, the DPIA and the deployment, the regulator’s questions and the engineer’s answers.
Authority you can rely on
Nine years working alongside Dean Armstrong KC. Clients guided through ICO investigations. Approval from the Bar Standards Board for Licensed Access, so we can instruct counsel directly on your behalf. And FRACT, an open standard for the sector.
What we believe
Trust belongs on the balance sheet.
The ability to prove you are trustworthy is capital, and it is worth investing in.
Proportionality is the point.
It is not a brake on facial recognition. It is the reason the technology is allowed at all. A deployment that cannot show it is proportionate should not go ahead.
Bias is a fact to manage, not a slur to deny.
Nine years working alongside Dean Armstrong KC. Clients guided through ICO investigations. Approval from the Bar Standards Board for Licensed Access, so we can instruct counsel directly on your behalf. And FRACT, an open standard for the sector.
Function creep is the quiet risk.
A system installed for one purpose drifts to others unless someone draws the line. We help you draw it, and write it down.
Candour is the only sustainable strategy.
When something goes wrong, the true account is the only one an organisation can safely maintain.
How we work
Candid
We tell you what we think, including when it is not what you hoped to hear. Data compliance should be a business enabler not a business blocker.
Necessary and Proportionate
Few advisers are fluent in both. We understand the lawful basis and the algorithm, the DPIA and the deployment, the regulator’s questions and the engineer’s answers.
Practical
Nine years working alongside Dean Armstrong KC. Clients guided through ICO investigations. Approval from the Bar Standards Board for Licensed Access, so we can instruct counsel directly on your behalf. And FRACT, an open standard for the sector.
Practising what we preach
This website was built to the standards we advise on: privacy by design, accessibility to WCAG 2.2 AA, and lawful analytics.
Our team
A small senior team that combines the law, policing, security, governance and commerce. Every client works directly with the people named here.
Richard Dutton
Managing Director & Co-Founder
The conviction that trust belongs on the balance sheet.
Richard co-founded ELIAS and leads the practice. A Cambridge law graduate with a thirty-year career in senior management across marketing services, digital media, not-for-profit and healthcare, he pairs commercial instinct with deep data-protection expertise. An experienced Data Protection Officer, he brings nine years of board-level governance, having served as Deputy Chairman, Senior Independent Director and Chair of the Finance and Performance Committee of a large NHS Foundation Trust. He is a former Fellow of the Institute of Data and Marketing, a Certified Loyalty Marketing Professional and a founding Regent of the Loyalty Academy. Richard’s conviction runs through everything ELIAS does: that compliance, done well, is not a cost but a company’s most valuable asset.
Chris Greany
Chairman
Three decades at the front line of security, fraud and cyber.
Chris chairs ELIAS and brings more than thirty-five years across the corporate, governmental and law-enforcement worlds. In the private sector he has advised FTSE 100 boards, regulators and governments on cyber and information-security risk. As a police Commander and national lead he drove the growth of the UK’s fraud and cyber-crime reporting centre and helped shape CyberUK; he sat on the Government’s Ministerial Board on Cyber Security and contributed to the creation of the National Cyber Security Centre. A published author and commentator, Chris is a Strategic Advisory Council member of the International Security and International Cyber Expo.
James Farrell
Non-Executive Director
Where the law meets covert technology.
James is a solicitor whose career bridges regulatory law and technical surveillance — a combination few can offer. He has advised companies and individuals under investigation by bodies including HM Revenue and Customs and the Football Association, prosecuted fraud on behalf of Trading Standards, and represented clients interviewed under caution by the ICO. Before qualifying, he served as Head of Operations for the Metropolitan Police’s Covert Technical Surveillance Unit, directing the deployment of surveillance technology in the investigation of serious crime and terrorism, nationally and internationally. He advises across GDPR and data-protection compliance, from breach response to the lawful use of surveillance technology.
Jill Dutton
Project Lead & Company Secretary
The detail behind the delivery.
Jill is a founding shareholder of ELIAS and the operational engine of the practice. After a twenty-five-year career with the largest US airline, she relocated to the UK in 2016, bringing a managerial and customer-service discipline — and a relentless attention to detail — that has been central to ELIAS’s success. She holds an MBA in Marketing and Management and serves as Company Secretary, project-management lead, and the guardian of client-service standards and back-office operations.
Counsel we work with
Our advice is underpinned by eminent counsel. We are approved for Licensed Access by the Bar Standards Board, which means clients reach the Bar through us, without delay.
Dean Armstrong KC
Legal Counsel (in association)
Silk at the sharp end of data and information law.
For nine years ELIAS has worked alongside Dean Armstrong KC and his team to give clients a legally defensible position under the UK GDPR and the Data Protection Act 2018. One of the country’s leading silks on data and information law, Dean’s counsel underpins ELIAS’s advice at the highest level and anchors the firm’s authority on the lawful deployment of facial recognition.
