Grillo LLP – Chartered Surveyors is committed to protecting your privacy. This statement describes how we collect and use personal information about people who interact with us or visit our website and / or through any of the firms Social Media Pages. This policy is concerned with how we collect information, what we do with and what controls you have. The terms of this statement may change, so please check it from time to time.
This document refers to personal data. Personal information is any piece of information that relates to a living, identifiable human being (hereafter will be called the Data Subject). This could be people’s names, contact details, financial details, photos, etc.
The Data Protection Act (DPA), Privacy and Electronic Communications Regulations (PECR) and The General Data Protection Regulations (GDPR) seek to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU.
If you have any queries about this privacy statement, please call 01483 860 600 or email email@example.com.
2. Who we are
Grillo LLP – Chartered Surveyors is an independent, private surveying firm, principally offering, residential and commercial property, and architectural services. The practice is recognised as one of the most highly professional in the area of Surrey, with a reputation built on the highest standards and utmost levels of personal service. We are a Limited Liability Partnership and we are located at 4 Church Street, Godalming, Surrey, GU7 1EH.
3. Personal Data
We collect information from you in the following ways:
- through our website, including cookies (please refer to the relevant cookie notice for further details)
- email, post and mail correspondence with us
- contact via phone
- application and request forms by post
- in-person contact with Grillo LLP – Chartered Surveyors employees
- information we receive from external third parties
4. What information do we collect from you?
We will collect different kinds of information from you depending on our relationship with you.
We may collect the following information from you:
- Contact Information.
- Demographic information.
- Other information in relation to fulfilling our contractual obligations.
- Information in relation to marketing purposes.
- If you apply for a job at Grillo LLP – Chartered Surveyors, we will collect enough data to process your application.
We also gather general information about the use of our website, such as which pages users visit most often and which services, events or facilities are of most interest. We may also track pages users visit when they click on links in emails from us. We may use this information to personalise the way our website is presented when users visit, to make improvements to our website and to ensure we provide the best service for users. Whenever possible, we use aggregated or anonymous information that does not identify individual visitors to our website.
5. What do we do with the information?
Personal information collected and processed by us may be used, for the following purposes:
- To update you on our activities and your relationship with Grillo LLP – Chartered Surveyors where we have a lawful basis to do so.
- To allow you to participate in interactive features on our website, when you choose to do so.
- To analyse and improve the services offered on our websites by providing you with the most user-friendly navigation experience we can for your computer or other internet device
- To process your personal information for the purposes of customer analysis, assessment and direct marketing, on a personalised or aggregated basis, to help us with our activities and to provide you with the most relevant information.
- To develop our systems and relationships with you
- When we are legally required to hold certain personal information to fulfil our statutory obligations:
- The collection of Income Tax and transferring of Income Tax/PAYE information to HM Revenue & Customs.
- Bank details in connection with payments.
- For insurance reasons and accident reporting.
- To determine you have a valid driving license.
- Validating your right to work in the UK and for occupational health assessments.
- Administration and archiving including contacting you if we require further information to process your job application form.
- Transferring your personal data to organisations we work with to achieve our objectives.
- We will also hold information about your details so that we can respect your preferences for being contacted by us.
- Providing fee quotations
- To meet our contractual obligations
We will only collect the information needed so we can provide you with services relating to our business services.
We do not sell or broker your data.
6. Lawful Bases, Consent and Legitimate Interest
We must have a lawful basis to process your personal data and we have determined our lawful bases to process your data:
We use the following legal basis for processing personal data:
- A consent from an individual.
- A contract with an individual.
- To be in compliance with a legal obligation.
- Legitimate interests.
Where possible we will endeavour to collect opt-in consent from you, specifically when we employ you or you meet us at face to face.
If we do not hold consent, we can use contractual reasons to process your data or contact you, and we may also use legitimate interests as our justification. This enables us, in certain circumstances, to process your data without having your prior consent or any other lawful basis. We have given due consideration to which types of processing fall within the legitimate interests of individuals.
We will always ensure the privacy rights of the individual are given due consideration and any potential harm is identified before processing data in this way, via conducting a Legitimate Interest Assessment.
7. Legitimate interests pursued by Grillo LLP – Chartered Surveyors and/or its Clients
To promote the services offered by Grillo LLP – Chartered Surveyors and/or to market the services and/or products offered by us to existing Clients. We will ensure that the content of our communication is of a relevant interest to you. We may send you information about our services and other activities.
If at any time you want to alter your preferences or request that we stop processing your information, please let us know by calling us on 01483 860 600 or email firstname.lastname@example.org.
We will not make marketing calls to you (individual or business) if you are registered with the Telephone Preference Service (TPS) unless you have given us consent that you are happy to receive calls from us.
You may still receive other types of telephone calls, for administration purposes from us, as long as they are not marketing calls. We do not record/ monitor telephone calls.
9. Who do we share information with?
We will never sell or rent your personal information to other organisations. We only disclose information when obliged to by law, for employment, for purposes of national security, taxation, accident reporting, right to work, criminal investigations and the following:
- When we use other companies to provide services on our behalf, e.g. payment processing, mailing or delivering communications, for employment reasons, answering customers’ questions about products or services, sending mail and emails, customer analysis and marketing, training, fulfilling contracts, statutory requirements, when using auditors/advisors.
Where we use third parties we will make sure there are appropriate controls in place, and the third parties must always have signed a confidentiality agreement or contract where your data is kept securely and only used for the purpose of the Grillo LLP – Chartered Surveyors project for which they have been appointed. We will ensure that our contracted third parties will not keep your information, and will only use it on our behalf and as we have instructed.
Grillo LLP – Chartered Surveyors 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 Grillo LLP – Chartered Surveyors, its clients and/or the wider community.
10. Retention Policy
If you cease your association with us, any personal information you supply to us will not be retained for longer than necessary and will be removed from our systems or securely disposed of in accordance with the requirements of our Data Protection Policy and our retention periods.
Grillo LLP – Chartered Surveyors will process personal data during the duration of any contract and will continue to store only the personal data needed for the following number of years:
- Fee Quotations – 1 year.
- Job applications including CVs – 3 months.
- Files relating to professional work carried out by Grillo LLP – Chartered Surveyors – 15 years.
- Absence during pregnancy and Statutory Maternity Pay (SMP) – 3 years after the end of the tax year in which the employee’s maternity pay period ended.
- Statutory Paternity Pay (SPP), Statutory Shared Parental Pay (ShPP) and Statutory Adoption Pay (SAP) – 3 years after the end of the tax year in which payments of SPP, ShPP or SAP were made.
- Wages and deductions (Payroll/PAYE) – 7 years after the end of the income tax year to which the records relate.
- Accounting and company transactions – In the case of a private company, for 3 years from the date on which they are made; and in the case of a public company, for 6 years from the date on which they are made.
- VAT accounts, tax invoices, imports and credit and debit notes – 7 years.
- Corporation tax – 7 years.
- Accidents at work and work-related illness – 4 years from the date on which the record was made.
- Injuries, fatalities, diseases and dangerous occurrences – 4 years from the date on which the record was made.
- Risk assessments – 4 years.
- Exposure to specified hazardous substances – 40 years from the date of the last entry made in it.
At the expiry of the above retention periods any personal data not needed, will be irreversibly deleted.
11. Data storage
Data is held in the United Kingdom/European Union using different (multiple) servers. Grillo LLP – Chartered Surveyors does not store personal data outside the European Economic Area (EEA).
We take appropriate measures to ensure the personal information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used.
12. Your rights as a data subject
At any point whilst Grillo LLP – Chartered Surveyors 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 to 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 to be subject to the legal effects of automated processing or profiling.
You have a choice about whether you want to receive information about our progress and activities.
We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted.
If for any reason you wish to have your personal details removed/rectified/change of use from our records, please contact us. You can change your preferences or any information, at any time or make a formal complaint by contacting our Office Manager either by phone 01483 860 600 or emailing us (email@example.com). You can also request a Subject Access Request to view data we may hold on you. We will of course ask you to confirm your identity.
In the event that Grillo LLP – Chartered Surveyors refuses your request under rights of access, we will provide you with a reason as to why, which you have the legal right to challenge.
13. Grillo LLP – Chartered Surveyors at your request can 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 (Grillo LLP – Chartered Surveyors) that has determined how and why to process your data.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Grillo LLP – Chartered Surveyors 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 to whom 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 Information Commissioners Office (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 wasn’t 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.
14. To access what personal data is held, identification will be required
Grillo LLP – Chartered Surveyors will accept the following forms of ID when information on your personal data is requested:
A copy of your current 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 Grillo LLP – Chartered Surveyors is dissatisfied with the quality, further information may be sought before personal data can be released.
In most cases we will not charge for this service, but we may apply a charge if the request is excessive or repetitive.
All requests should be made by phoning 01483 860600 or writing to us at the address further below or email firstname.lastname@example.org
In the event that you wish to make a complaint about how your personal data is being processed by us, you have the right to complain to the Partners (LLP Members)
Grillo LLP, attention of the Partners (LLP Members)
4 Church Street, Godalming, Surrey, GU7 1EH
Telephone 01483 860 600 or email email@example.com
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Please let us know if a link is not working (use the ‘Contact us‘ link which can be found on our website).
In purchasing goods or services from any of the companies to which any Grillo LLP – Chartered Surveyors sites links, you are forming a contract with the company(s) concerned (agreeing to their terms and conditions), not Grillo LLP – Chartered Surveyors.
18. Using our social media pages
While this statement covers our privacy practices and how we will use any information collected from our websites and social media pages, it doesn’t cover how providers of social media websites will use your information.
You should read the social media site’s privacy policies.
19. Posting content on our websites and social media pages
Remember that the internet provides instant worldwide access. Any information that you provide will be worldwide instantly.
We don’t moderate our website or Social Media Pages. So, if you post comments about other people it’s not only your privacy that is at stake. Protect your friends’ privacy and reputations. Be careful about uploading any content that may show you or your friends in compromising situations and be aware that other users may abuse the content you have provided.
Please don’t provide information about yourself or other people unless you’re sure you and they are happy to have it made public. In particular, don’t provide any information about others without their consent where that information might identify them, such as:-
- Tagged photos
Under no circumstances make public other peoples’ home address, email addresses or contact numbers.
We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control and these are documented in our internal Security Policy and Data Protection Policy. Whilst we can’t ensure or guarantee loss, misuse or alteration of information won’t occur, we’ll use standard industry methods to prevent this.
Unfortunately, the transmission of information across the internet isn’t completely secure and whilst we do our best to try to protect the security of your information, we can’t ensure or guarantee that loss, misuse or alteration of information won’t occur whilst you or we are transferring this information.
If you are aged under 16, please ensure you obtain your parent/guardian’s consent before sending any personal information to any website or directly to Grillo LLP – Chartered Surveyors. We will seek verification of age, if necessary, with your parent/guardian.
This policy was last reviewed in August 2018. The content of the policy may be reviewed and changed without prior notice, please visit the policy for any changes. By continuing to use our website you will be deemed to have accepted such changes.
Regulated by RICS