Croydon: 020 8686 4400

Policies

PFG PROPERTIES T/A G & P PROPERTY
This page details the following policies:

- Privacy & Cookie Policy
- Complaints Policy
- Anti-bribery and anti-corruption Policy
- Modern Slavery Policy

Privacy & Cookie Policy

The Policy sets out how PFG Properties T/A G & P Property uses and protects any information that you give when you use this website.

We are committed to safeguarding the privacy of your data whilst providing a personalised and valuable service. Should we ask you to provide certain information by which you can be identified
when using this website, then you can be assured that it will only be used in accordance with this
privacy statement.

This Privacy and Cookie Policy applies to all personal data as defined in the The General Data Protection Regulations (GDPR).

If you have any requests concerning your personal information or any queries with regard to these
practices please contact us by email on info@gpcommercial.co.uk.


PFG Properties T/A G & P Property may change this policy from time to time by updating this page, you should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 25th May 2018 (Updated October 2021).
G & P Property has appointed a Data Protection Officer who is in charge of privacy-relatedmatters.


Contact: Nick Payne,
MRICS, G & P Property,
31 Station Road West,
Oxted, RH8 9EE
Tel 01883 723888


Anyone who is not happy with any aspect of how G & P Property collects and uses their data has the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). However, G & P Property would be grateful for prior notification of the complaint so they can try to resolve it in the first instance Information collected and its use:

What we collect:
We may collect the following information:

Identity:
Name, Company name and job title

Contact information including:
address, email address and contact telephone numbers

Other information
relevant to customer property requirements such as sectors in which you are interested and geographic regions of interest.

Technical Data:
which may include internet protocol (IP) addresses, browser type and version browser pug-in types and versions, time zone setting and location, operating system platform and other technology on the devises used to access this website.

Profile Data:
which may include feedback and survey responses.

Usage Data:
which may include information about how visitors use the G & P Property website.

Marketing and communications Data:
which may which may include preferences in receiving
marketing and communications from G & P Property.

What we do with the information we gather:
We require this information to understand your property needs and provide you with a better service.
The website user may browse our website without providing any personal data. We only collect personal information that you freely provide to the company which is held and used for the following purposes:

Where information is submitted by you in relation to an enquiry about our services, for the purpose of responding to your enquiry.

If you subsequently appoint us to act for you, the information will be held in accordance with our data protection procedures for Clients. If you do not subsequently appoint us to act for you we may retain your details for the purpose of contacting you in the future about our services, unless you request us not to do so by emailing info@gpcommercial.co.uk

To send you email notifications which you have specifically requested.

To send you other newsletters and other marketing communications (relating to our business which we think may be of interest to you by email or similar technology) you can inform us at any time if you no longer require marketing communications to be sent by emailing us.

We may use the information to improve our marketing and services. We will not without your express consent provide your personal information to any third parties for the purpose of direct marketing.

Sensitive data:
G & P Property does not collect any sensitive data. Sensitive data refers to data that includes details about race or ethnicity religious or philosophical beliefs, sex life, sexual orientation, political opinions, health information and genetic and biometric data.
G&P Property does not collect any information about criminal convictions and offences.

Security:
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How we collect personal data:
G & P Property collects personal date through direct interactions through filling in forms on the G &
P Property website, or by postal communication, phone, email or otherwise.

Examples of instances of personal data collection include:

  • Request to receive regular mailing materials
  • A marketing or resources request
  • Contact via social media.

Automated technologies or interactions:
G & P Property may automatically collect technical data about equipment, browsing actions and usage patterns. This data is collected by using cookies, server logs and similar technologies.

Please see the G & P Property cookie policy for further details.

Third parties or publicly available sources:
G & P Property may receive personal data from various third parties and public sources as set out
below:

  • Technical data from social media
  • Analytics providers such as Google
  • Search information providers such as Google
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register


How G & P Property uses personal data:
G & P Property only uses personal data when legally permitted. The most common uses of personal data are shown below:

  • Where G & P Property needs to perform a contract with a prospect or customer
  • Where it is necessary for legitimate interests (or those of a third party) and fundamental
  • rights do not override those interests
  • Where G & P Property must comply with a legal or regulatory obligation

As a rule, G & P Property does not rely on consent as a legal ground for processing personal data, other than in relation to sending marketing communications via email or text message. You have the right to withdraw consent to marketing at any time by emailing: info@gpcommercial.co.uk.

Reasons for G & P Property to process personal data:
Set out below is why G & P Property uses personal data and the lawful reasons for which it will
process such data.

G & P Property may process your personal data for more than one lawful ground, depending on
the specific purpose for which we are using your data. Please email us: info@gpcommercial.co.uk

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 below.

Activity: Process and deliver marketing information, fees and charges and collecting any monies owed

Data description: identity, contact, financial, transaction, marketing and communications
Legal grounds for processing: performance of a contract and necessary for G & P Property to recover debt owed

Activity: register new customer Data description: identity and contact

Legal grounds for processing: performance of a contract. Delivery of property information and advice.

Activity: to safeguard the G & P Property site including troubleshooting, testing, system
maintenance, back-ups, support, data analysis, hosting, support and reporting.

Data description: technical, identity, contact Legal grounds for processing: ensure the day to day running of G & P Property, safeguarding network security and provide ongoing administration and IT services.

Activity: relationship management, including requesting a review or survey or notification
of changes to the G & P Property terms or privacy policy.

Data description: identity, contact, profile, marketing and communications.

Legal grounds for processing: performance of a contract, necessary to comply with a legal
obligation, required to keep the G & P Property

Activity: where relevant, recommend products or services that might be of benefit or interest

Data description: profile, identity, usage, contact, technical

Legal grounds for processing: legitimately necessary for G & P Property to grow its business

Activity: utilise data analytics to inform decisions relating to website build, services, marketing and visitor experience.

Data description: usage, technical

Legal grounds for processing: reasonably necessary to continually ensure products and services are relevant and meet customer/client needs.

Online and offline marketing communications for G & P Property
G & P Property will only send communications to those who have:

  • Specifically requested information from G & P Property or services; or
  • Those who have provided G & P Property with their details when registering for a promotion or marketing materials; and in each case, have not opted out of receiving those communications.

G & P Property will require a clear, opt-in consent before sharing personal data with any third party
for marketing purposes.

Using clear opt-out links, an instruction to G & P Property or third parties can be made to stop
marketing messages from being sent at any time via email: info@gpcommercial.co.uk.

Please note: An opt-out from receiving marketing communications does not apply to personal data
provided to G & P Property.

Disclosures of your personal data
G & P Property might have to share personal data with the following third parties:

  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances

  • Service providers who provide IT and system administration services

  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services

  • Third parties who G & P Property sell, transfer, or merge parts of their business or company assets.

G & P Property will request all third parties to respect the security of personal data and to treat it in
accordance with the law. G & P Property only allows such third parties to process personal data for
specified purposes and in accordance with G & P Property’s strict instructions.

Legal rights explained:
In certain circumstances, users can extend their rights under data protection laws in relation to personal data as follows:

  • To request access to personal data
  • To request correction of personal data
  • To object to processing of personal data
  • To request deletion of data
  • To restrict the processing of personal data
  • To request transfer of personal data
  • To exercise the right to withdraw consent

To carry out any of the above rights and actions, please contact: info@gpcommercial.co.uk

You can visit the following website for further information:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individualrights/

G & P Property will not levy a charge to access personal data, or for other rights to be exercised.

G & P Property may charge a fee if a request is clearly excessive or unfounded.

G & P Property may need to request additional information which is specific to confirm an identity
and to safeguard the right to access (or to exercise any other rights). This is a security measure to
ensure that personal data is not disclosed to any person who has no right to receive it.

G & P Property will try to respond to all legitimate requests within one month. If a request is deemed to require longer than a month to process, in such cases, G & P Property will notify the individual and keep them appraised of progress.


Data security:
G & P Property has implemented appropriate security measures to safeguard personal data from
being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition,
G&P Property restricts access to personal data to those employees, agents, contractors and
other third parties who have a business need to know such data. They will only process personal
data on the instructions of G & P Property and they are subject to a duty of confidentiality.

G & P Property has put in place procedures to deal with any suspected personal data breach and will notify an individual or any applicable regulator of a breach where it is legally required to do so.

Change of purpose:
G & P Property will only use personal data for the purposes for which it was gathered, unless G & P Property reasonably considers it should be used for another reason and that reason has synergy with the original purpose. To find out more about how the processing for the new purpose is compatible with the original purpose, please email: info@gpcommercial.co.uk

If G & P Property needs to use personal data for a purpose unconnected to the original purpose for
which it was gathered, G & P Property will notify the individual and fully explain the legal reasons
for processing.


Please note, G & P Property may process personal data without prior knowledge or consent where this is required or permitted by law.


Data retention:
G & P Property will only hold personal data for as long as is necessary to fulfil the purposes it was
collected for.

By law, G & P Property has to keep basic information about customers (including Contact, Identity,
Financial and Transaction Data) for six years after they cease being clients/customers for tax purposes.

To determine the appropriate retention period for personal data, G & P Property considers the
amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised
use or disclosure of personal data, the purposes for which G & P Property processes personal data
and whether G & P Property can achieve those purposes through other means, and the applicable
legal requirements.

G & P Property may anonymise personal data (so that it can no longer be associated with an individual) for research or statistical purposes, in which case, G & P Property may use this information indefinitely without further notice to the individual.

Third party links:
The G & P Property site includes links to third-party websites, plug-ins and applications. Clicking
on the links or enabling connections could allow third parties to collect or share data about a user.
In such cases, G & P Property does not control these third-party websites and is not responsible
for their individual privacy statements.

For further information on GDPR go to: https://ico.org.uk/for-organisations/guide-to-the-generaldata-protection-regulation-gdpr/

How we use Cookies:
A cookie is a small file which asks permission to be placed on your computer's hard drive. They
are used to help websites remember who you are, but cannot be used by themselves to identify
you.
To find out more about cookies and how you can configure your browser to accept or decline
cookies, we recommend you visit http://allaboutcookies.org for detailed guidance.

This website uses Google Analytics cookies.
We use Google analytics to collect information about visitor behaviour on our website. These are first-party cookies that store information about what pages you visit, how long you are on the website, how you got here and what you click on. This data is not tied to personally identifiable information and this cannot be used to identify who you are.

You can find out more about Google's position on privacy with regards to its analytics service at:
https://www.google.com/policies/privacy/

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Transmission of data
Whilst we have taken all reasonable steps to ensure that the information you provide will be kept secure from unauthorised access, we cannot guarantee that the information will be secure during transmission by you to this website.

Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following way:

  • If you have previously agreed to us using your personal information for us to send property marketing details that we are dealing with, you may change your mind at any time by writing to or emailing us at info@gpcommercial.co.uk


You have control
If at any stage you would like to remove, check or amend the information held by us about you please send an email to info@gpcommercial.co.uk or write to us at:


G & P Property
31 Station Road West
Oxted
Surrey, RH8 9EE

and we will take the necessary action within a reasonable time.

We also reserve the right to take reasonable steps to confirm your identity before making any disclosure of information held by us.

We will not sell, distribute or lease your personal information to third parties

  • unless we have your permission or are required by law to do so, or it is in connection with any legal proceedings or prospective legal proceedings
  • or in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk)

If you believe that any information we are holding on you is incorrect or incomplete, please write to
or email us as soon as possible at the above address.

We will promptly correct any information
found to be incorrect.

Enquiries regarding this policy should be directed to Nicholas Payne MRICS at G & P Property at
nickp@gpcommercial.co.uk 
or Telephone 01883 723888.

 

Complaints Policy
We hope that there will never be a reason to complain about any aspect of our service, however it is important to G & P Property that any dissatisfaction is dealt with speedily and effectively.

If you have any complaint you should not hesitate to contact:
Mr Nicholas Payne
G & P Property
31 Station Road West
Oxted
Surrey RH8 9EE

Where your complaint is initially made orally, whether fact-to-face or by telephone, you will be requested to send a written summary of your complaint to the person dealing with it.

Once we have received your written summary of the complaint, we will contact you in writing within
seven days to inform you of our understanding of the circumstances leading to your complaint.

You will be invited to make any comments that you may have in relation to this.

Within twenty-one days of receipt of your written summary, the person dealing with your complaint
will write to you, in order to inform you of the outcome of the internal investigation into your complaint and to let you know what actions have been or will be taken.

We operate a formal complaints handling procedure to deal with complaints relating to our service. The procedure is in accordance with the requirements of our governing body, the Royal Institution
of Chartered Surveyors (RICS) and complies with Rule 7 of the Rules of Conduct for Firms.

Where a complaint has not been resolved to your satisfaction we agree to the referral of the matter
to the mediation process run by the RICS.

Enquiries regarding this policy should be directed to Nicholas Payne MRICS at G & P Property at
nickp@gpcommercial.co.uk
or Telephone 01883 723888.

 

G & P Property - Anti-bribery and anti-corruption policy

What is bribery?
This is the act of offering something of value to influence a decision leading to an ultimate business
advantage or benefit.

To be more specific, it refers to offering, giving, asking, promising, agreeing, receiving something of value to influence a behaviour, action or decision.

G & P Property employees must not take part or engage in any form of bribery as it is an illegal act.

Policy contents
This anti-bribery policy sets out the responsibilities of G & P Property and everyone who works for us to observe and uphold our zero-tolerance position on bribery and corruption.

Policy statement
G & P Property is committed to conducting business in an ethical and honest way and is dedicated to implementing and upholding systems and processes that guarantee bribery is prevented. G & P Property does not tolerate acts of bribery and corrupt activities. We act professionally and fairly in all business dealings and relationships.

G & P Property will respect and uphold all laws in relation to anti-bribery and corruption in all the
jurisdictions in which we operate. We work and are bound to the laws of the UK, including the
Bribery Act 2010, relating to our conduct both in the UK and overseas.
G & P Property understands that bribery and corruption is not tolerated and punishable by up to
ten years of imprisonment and a fine. If G & P Property is found to have taken an active role in corrupt activities, we may be liable to an unlimited fine, face exclusion from tendering for public contracts, and receive negative public relations. With this in mind, we take our legal responsibilities very seriously.

Who this policy covers
This policy covers all employees and associated third parties:

  • Permanent
  • Part-time
  • Contractors
  • Consultants
  • Apprentices
  • Agency staff
  • Sponsors
  • Any persons associated with us
    (including suppliers and third parties)

Any agreements or arrangements G & P Property makes with a third party is subject to clear
contractual terms including the requirement for the third party to comply with minimum acceptable
standards and procedures relating to anti-bribery and corruption.

Kickbacks and facilitation payments
We understand facilitation payments are a form of bribery and we will not accept or make any form
of facilitation payments of any kind.

Kickbacks are not tolerated at G & P Property. We recognise that kickbacks are made in exchange
for a business advantage or favour.

Gifts and hospitality
We accept appropriate gestures of goodwill and hospitality. However, the giving and receiving of
gifts must meet the following requirements:

  • It is appropriate to the situation or circumstance, e.g. a box of chocolates for
  • Christmas and to thank the company for their help in completing a large project It is not made with the expectation that a return favour must be reciprocated
  • It is not given to a key individual with the clear intention to influence them
  • It must be given in a company name – not an individual It must not contain cash
  • It complies with local law
  • It is not made with the intention of influencing the third party to whom it is being given or to receive a business advantage of any kind
  • It is not given in secret
  • It is not above £100

On some occasions it may be inappropriate On some occasions it may be inappropriate to decline an offer of a gift, e.g. when meeting with someone from another culture who may take offence if a gift is declined.

All gifts given and received are disclosed to our compliance manager – especially those from suppliers.

Our responsibilities
We ensure our employees read, understand and comply with the information contained in this
policy and any training or other anti-bribery and corruption information given.

If any of our employees breach this policy, they will face disciplinary action and dismissal for gross
misconduct. We have the right to terminate a contractual relationship with an employee if they
breach this anti-bribery policy.

Raising a concern
If you believe there is bribery or corrupt activities taking place in connection with G & P Property,
please express your concern as early as possible. We would ask that you speak with Nick Payne
MRICS.

Political and charitable contributions
G & P Property will not support any political parties by making improper donations in cash, or kind,
to gain an improper business advantage.
We encourage raising and donating money for good causes that resonate with our business
values. We disclose all charitable donations we make.
We ensure our employees understand charitable contributions are not used to facilitate and
conceal acts of bribery.

Dealing with bribery or corruption
Please tell our compliance manager if you feel a bribe or corrupt behaviour is taking place in relation to G & P Property. This might involve being offered a bribe or being coerced into making a bribe – or if you feel you are a victim of some form of corrupt activity.

Safeguarding and protection
As a result of refusing to accept or offer a bribe, G & P Property will make sure no one receives adverse treatment due to reporting the concern.

Adverse treatment refers to disciplinary action, dismissal or detrimental treatment in connection to
the concern raised.

Communication
Our anti-bribery and corruption policy will be clearly communicated to all employees, contractors,
suppliers and third parties at the outset of any working relationship.

Record keeping
G & P Property will record and keep accurate financial documents and have the necessary internal controls and processes in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.

Ongoing review
Our Director monitors and reviews this policy on a regular basis.

This policy does not form part of an employee’s contract of employment and G & P Property may
amend it at any time to improve its effectiveness at dealing with bribery and corruption.

Our internal control processes and procedures have been written to prevent bribery and corruption
and are subject to regular reviews and audits to ensure they continue to work effectively.

 

G & P Property – Modern Slavery Policy
We are committed to ensuring there is no modern-day slavery or human trafficking in any part of the business.

Our anti-slavery policy statement reflects our commitment to acting ethically and with integrity in
our business relationships. We will not support or deal with any business knowingly involved in slavery or human trafficking.

The senior management team shall take responsibility for implementing this policy statement and its objectives and provide adequate resources (training, etc.) to ensure that slavery and human trafficking is not taking place within the organisation. The company’s anti-slavery policy will be displayed on the company website.

All new and existing employees are subjected to Right to Work checks to ensure that G & P Property does not employ illegal workers thereby ensuring compliance with the Immigration, Asylum and Nationality Act 2016.

Employees are required to immediately report any possible breach of the code of conduct. This policy applies to all those employed by G & P Property. The policy will be regularly reviewed to ensure its continuing suitability.