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Policies & procedures

Williams Gunter Hardwick Code of Conduct and Policies

At Williams Gunter Hardwick we are committed to undertaking business in a responsible and ethical way. The firm owes much of its’ success and personality to the provision of a first class service to its’ clients and ethical behaviour in relation to all parties with which it has a business relationship.

Health & Safety

Williams Gunter Hardwick considers high standards of health and safety as an important factor both in the workplace and out on site. We take the safety of our people and those with which we work seriously and we strive to ensure that we do not place them in positions of risk or danger. To comply with this policy and the firm’s security policies, procedures and practices  we all assume responsibility for taking proper precautions to protect ourselves and those with which we work. We ask that employees report unsafe, insecure or unhealthy conditions immediately to enable us to solve them in a timely manner.

Drugs and alcohol at work

We are required to report to work fit to perform our jobs. Inappropriate use of alcohol or the use of any non-prescription drugs or controlled substances during our working time is prohibited. Failure to adhere to this policy may result in disciplinary action.

Discrimination

Williams Gunter Hardwick is an equal opportunity employer and requires all of its’ people to treat others with respect irrespective of race, creed, gender, religion, marital status, age, or disability. Williams Gunter Hardwick expects this conduct to be mirrored by those organisations with which it works.
The firm will not tolerate any instances of bullying or victimisation within the workspace.

Price sensitive information

In certain instances the firm may be privy to price sensitive information and under such circumstances the information must be kept confidential and not revealed outside the firm. Any such revelations will be regarded as a breach of the firm’s policy on confidentiality.

Conflicts of Interest

Williams Gunter Hardwick has a policy for integrity and trust. The firm must avoid instances where a conflict of interest may arise, whereby the ability to offer impartial and objective advice is compromised due to existing obligations to another client or where personal commitments or relationships prevent impartial advice being provided. The firm will not engage in property dealings that will give rise to a potential conflict of interest.

Gifts

Occasionally modest gifts may be exchanged in a business context.  No gifts should be exchanged that can result in negative outcomes or give rise to unfair advantage.   All gifts accepted or given should be appropriate and in proportion to the value of the relationship between the parties.
Gifts that would result in the recipient feeling beholden to the donor should be politely refused.

Anti- Bribery and Corruption

The firm is subject to the Bribery Act 2010. We will refrain from accepting or making any payment or commitment which could be construed as an inducement for an action which is illegal or unethical. The firm and its’ people will not misuse and entrusted power for personal gain.

Complaints

The firm has a complaints policy which is set out below.
Any complaints should be addressed to Andrew Hardwick (andrew@wghproperty.co.uk) in the first instance. If the complaint cannot be resolved by direct contact the firm has an established formal complaint handling referral process.

Anti-Money Laundering

The firm complies with the HMRC requirements relating to Anti-Money Laundering.
The Directors are responsible for ensuring that appropriate Anti-Money Laundering Checks are in place.
Appropriate Anti-Money Laundering checks should be in place before appropriate instructions are undertaken.
A proper process is in place in the event that a prospective client fails an Ant-Money Laudering check.
All fee earners are trained to remain alert for suspicious transactions.
Evidence of Anti-Money Laundering checks are retained.
Anti-Money Laundering training is given to all staff.
Processes exist to monitor Anti-Money Laundering process compliance.

Environmental Awareness

Williams Gunter Hardwick takes the effect that its’ activities have on the environment and as such it is our policy to minimise environmental harm caused by our activities. The firm will comply with environmental laws and the firm recognises that it has a serious role in mentoring environmental best practice and responsibility. The firm enforces a recycling policy and strives to make transport choices leading to the lowest environmental impact.

Williams Gunter Hardwick complaint handling procedure

This note outlines the procedure we will follow in dealing with complaints relating to our services.
The procedure is in accordance with the requirements of The Royal Institution of Chartered Surveyors and complies with Rule 7 of the Rules of Conduct for Firms.

Our complaints officer is Andrew Hardwick, Williams Gunter Hardwick, Clifton Heights, Triangle West, Clifton, Bristol  BS8 1EJ
Telephone 0117 922 1222, Mobile 07771 820053, email andrew@wghproperty.co.uk

If you have a complaint or a question please contact him.

If your complaint is about Andrew Hardwick, please contact one of the other two directors, Malcolm Gunter or Stuart Williams.

If you have made your initial complaint verbally please also make it in writing to Andrew Hardwick.

Once we have your written complaint Andrew Hardwick will contact you within 7 working days to acknowledge the complaint and he will outline Williams Gunter Hardwick’s understanding of the complaint. He will invite you to make further comments about the circumstances of the complaint.

Within 28 days of receiving the written complaint we will write to you to inform you of the outcome of internal investigations into the complaint to let you know what actions we have taken or will take.

If you remain dissatisfied with any aspect of the handling of the complaint and your complaint is of a business nature then we will strive to resolve the complaint swiftly through negotiations. If this is not possible we agree to enter into mediation with you in accordance with the Arbitration Procedure for Surveying Disputes.

The contact details for the Arbitration Procedure for Surveying Disputes are :-

CEDR
70 Fleet Street
London  EC4Y 1EU

Tel 0207 536 6060

Alternatively if your complaint is not of a business nature, we agree to refer the complaint to the Ombudsman Services : Property (OS:P). This service is free to the consumer.

The contact details for Ombudsman Services are :-
Ombudsman Services : Property
Po Box 1021
Warrington WA4 9FE

Tel 0330 440 1634 or 01925 530 270

GDPR & Data Protection

The firm will not abuse personal data which it collects and it will not knowingly pass this information to any third parties.

Privacy Policy Statement

Contents

1 Policy ……………………………………………………………………………………………………………………

1.1 Why this policy exists …………………………………………………………………………………………..

1.2 Scope ………………………………………………………………………………………………………………..

2 Key Areas ……………………………………………………………………………………………………………..

2.1 Data Protection Law …………………………………………………………………………………………….

2.1.1 General Data Protection Regulations (GDPR) ………………………………………………………

2.2 Responsibilities ……………………………………………………………………………………………………

2.3 Employee Guidelines …………………………………………………………………………………………..

2.4 Data Storage ……………………………………………………………………………………………………….

2.5 Working with Personal Data …………………………………………………………………………………..

2.6 Data Accuracy ……………………………………………………………………………………………………..

2.7 Subject Access Requests ………………………………………………………………………………………

2.8 Request for Personal Data from other Agencies ……………………………………………………….

3 Policy Enforcement ………………………………………………………………………………………………….

4 Related Documents …………………………………………………………………………………………………

1 Policy

This company’s activities require it to gather and use certain information about individuals. Information

can include customers, suppliers, business contacts, employees and other people with which the

organisation has a relationship or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the

company’s data protection standards and to comply with the law.

The policy should be read alongside other key policies.

1.1 Why this policy exists

This data protection policy ensures that the company:

  • Complies with data protection law and follows good practice;
  • Protects the rights of staff, clients, applicants and all individuals of whom details are stored
  • Is open about how it stores and processes individuals’ data;
  • Protects itself from the risks of a data breach.
  • This policy helps to protect the company from data security risks, including:
  • Breaches of confidentiality. For instance, information being given out inappropriately;
  • Failing to offer choice. For instance, all individuals should be free to choose how the company
  • uses data relating to them;
  • Reputational damage. For instance, the company could suffer if hackers successfully gained
  • access to sensitive data.

1.2 Scope

This policy applies to all employees and any contractor, suppliers or others working on behalf of the

company. It applies to all data that the company holds relating to identifiable individuals, even if that

information technically falls outside of the Data Protection Act 1998. This includes:

  • Names of individuals;
  • Postal addresses;
  • Email addresses;
  • Telephone numbers;
  • Financial details;

 

2 Key Areas

2.1 Data Protection Law

The Data Protection Act 1998 describes how organisations must collect, handle and store personal

information.

These rules apply regardless of whether data is stored electronically, on paper or on other

materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not

disclosed unlawfully.

The Data Protection Act is underpinned by eight important principles. These say that personal data

must:

  • Be processed fairly and lawfully;
  • Be obtained only for specific, lawful purposes;
  • Be adequate, relevant and not excessive;
  • Be accurate and kept up to date;
  • Not be held for any longer than necessary;
  • Processed in accordance with the rights of data subjects;
  • Be protected in appropriate ways;
  • Not be transferred outside the European Economic Area (EEA), unless that country or territory

also ensures an adequate level of protection.

2.1.1 General Data Protection Regulations (GDPR)

With effect from 25th May 2018, GDPR extends the protection and requirements specified by the Data

Protection Act. This policy may be subject to change as the company’s systems and policies are

modified to conform to GDPR.

2.2 Responsibilities

Any employee that handles personal data must ensure that it is handled and processed in-line with this

policy and data protection principles.

However, the following have key areas of responsibility:

  • The company directors are ultimately responsible for ensuring that the company meets its legal

obligations;

  • The data protection officer is responsible for:
  • Keeping the company updated about data protection responsibilities, risks and issues;
  • Reviewing all data protection procedures and related policies
  • Arranging data protection training and advice for the people covered by this policy;
  • Handling data protection questions from staff and anyone else covered by this policy;
  • Dealing with subject access requests from individuals to see the data held about them;
  • Checking and approving any contracts or agreements with third parties that may handle

the personal data.

  • Ensuring all systems, services and equipment used for storing data meet acceptable security standards;
  • Performing regular checks and scans to ensure security hardware and software is

functioning properly;

  • Evaluating any third-party services the company is considering using to store or

process data.

  • The company directors are responsible for approving any data protection statements attached

to communications such as emails and letters.

2.3 Employee Guidelines

  • Employees should only be permitted to access data covered by this policy if it is required by

their job description;

  • Data should not be shared informally.
  • Employees should keep all data secure, by taking sensible precautions and following the

guidelines below;

  • In particular, strong passwords must be used and they should never be shared;
  • Personal data should not be disclosed to unauthorised people, either within the company or

externally;

  • Data should be regularly reviewed and updated. If no longer required, it should be deleted and

disposed of;

  • Employees should request help from the data protection officer if they are unsure about any aspect of data protection.

2.4 Data Storage 

These guidelines describe how and where data (both electronic and printed out) should be safely stored:

  • Employees should make sure paper and printouts are not left where they could be accessed

by an unauthorised person;

  • Data printouts should be disposed of securely when no longer required.
  • When data is stored electronically, it must be protected from unauthorised access, and malicious hacking attempts.
  • Data should be protected by strong passwords that are changed regularly and never shared

between employees.

  • If data is stored on removable media (like a CD or USB), these should be kept locked away

securely when not being used.

  • Data should only be stored on designated drives and servers.
  • Data should be backed up frequently. Those backups should be tested regularly, in line with

the company’s standard backup procedures.

  • All servers and computers containing data should be protected by approved security software

and a firewall.

2.5 Working with Personal Data

  • Personal data should not be shared informally.
  • Employees should not save copies of personal data to their own computers.

2.6 Data Accuracy

The law requires the company to take reasonable steps to ensure data is kept accurate and up to date.

It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept

as accurate and up to date as possible.

  • Data will be held in as few places as necessary. Staff should not create any unnecessary

additional data sets;

  • Staff should take every opportunity to ensure data is updated.
  • Data should be updated as inaccuracies are discovered. For instance, if a person can no

longer be contacted on their stored telephone number or email address, it should be removed from the database.

2.7 Subject Access Requests

All individuals who are the subject of personal data held by the company are entitled to:

  • Ask what information the company holds about them and why;
  • Ask how to gain access to it;
  • Be informed how to keep it up to date;
  • Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request.

Subject access requests from individuals should be made by email, addressed to the data controller at

info@wghproperty.co.uk. The data controller will aim to provide the relevant data within 14 days.

The data controller must verify the identity of anyone making a subject access request before handing

over any information.

2.8 Request for Personal Data from other Agencies

Under certain circumstances, the Data Protection Act allows personal data to be disclosed to law

enforcement agencies without the consent of the data subject.

Under these circumstances, the company will disclose the requested data. However, the data controller

will ensure the request is legitimate, seeking assistance from the company’s legal advisers where

necessary.

3 Policy Enforcement

Employees breaching this policy may be subject to disciplinary action. Where breaches may be

considered to amount to criminal behaviour, the company will involve the police or other law

enforcement agencies.