Last updated: 1st October 2024
SG Property Ventures Ltd along with its parent undertakings, subsidiaries and trading names, collectively known as SG Property Ventures (“us”, “we”, or “our”) operates www.sgpv.co.uk (the “Site”). This page informs you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site.
We use your Personal Information only for providing and improving the Site or to contact you should you choose to request further information from us. By using the Site, you agree to the collection and use of information in accordance with this Policy.
SG Property Ventures Ltd along with its parent undertakings, subsidiaries and trading names, known collectively as SG Property Ventures (“the Group”, “SGPV”) is committed to a Policy of protecting the rights and privacy of individuals.
We act in accordance with the UK General Data Protection Regulations and the UK Data Protection Act 2018, as may be amended from time to time. The Regulations along with the provisions of the Act are collectively referred to in this Policy as “UK DPA”.
UK DPA contains provisions that the organisation will need to be aware of as data controllers, including provisions intended to enhance the protection of personal data.
UK DPA requires that:
To ensure we comply with our various legal obligations, including the obligations imposed on it by UK DPA, the Group commits to ensuring that all information about individuals is collected and used fairly, stored safely and securely, and not disclosed to any third party unlawfully.
All members of staff are responsible for ensuring that any personal information which they hold is kept securely and not disclosed to any unauthorised third parties. The Group will ensure that all personal information is accessible only to those who have a valid reason for using it. We will have in place appropriate security measures to protect information physically and electronically.
As a matter of best practice, other agencies and individuals working with the Group and who have access to personal information, will be expected to read and comply with this Policy. It is expected that departments who are responsible for dealing with external bodies will take the responsibility for ensuring that such bodies sign a contract which among other things will include an agreement to abide by this Policy.
Consent as a basis for processing information although not always necessary is the best way to ensure that information is collected and processed in an open and transparent manner. Consent is especially important when SGPV is processing any sensitive information, as defined by the legislation. The Group understands consent to mean that the individual has been fully informed of the intended processing and has signified their agreement.
SG Property Ventures also confirms consent cannot be inferred from the non-response to a communication.
This Policy will be updated as necessary to reflect best practice in information management, security, and control and to ensure compliance with any changes or amendments to the UK DPA and other relevant legislation.
This Policy applies to all staff of the Group. Any breach of this Policy or of the Regulation itself will be considered an offence and the Group’s disciplinary procedures may be invoked.
Where there is a 3rd Party Data processor, the group will monitor the processor's policies and procedures and reserves the right to audit the 3rd party.
To comply with its obligations, SGPV undertakes to adhere to the eight principles:
We will make all reasonable efforts to ensure that individuals who are the focus of Personal Identifiable Information (“PII”) are informed of the identity of the data controller, the purposes of the processing, any disclosures to third parties that are envisaged; given an indication of the period for which the data will be kept, and any other information which may be relevant.
The Group will process the data for the specific and lawful purpose for which it was collected and not further process the data in a manner incompatible with this purpose. The Group will ensure that the reason for which it collected the data originally is the only reason for which it processes that data, unless the individual consents to any additional processing before it takes place.
SG Property Ventures undertakes not to disclose personal data to unauthorised third parties. Legitimate disclosures may occur in the following instances:
Where CCTV systems operate within the Group for the purpose of protecting staff and property, SG Property Ventures will only process personal data obtained by the CCTV system in a manner which ensures compliance with the legislation.
Individuals have a right to access any personal data relating to them which is held by SGPV.
We will use reasonable efforts consistent with our legal duty to supply, correct or delete personal information about you on our files.
Any individual wishing to exercise this right should apply in writing to the Data Protection Officer.
Any member of staff receiving a SAR should forward this to the Data Protection Officer. To ensure security we require you to prove your identity with 2 pieces of approved identification before any SARs request can be released.
It is the responsibility of the individuals giving their personal data to ensure that this is accurate, and each individual should notify the Company if a change in circumstance means that the data needs to be updated.
It is Our responsibility to ensure that any notification regarding the change is noted and acted on.
The Group undertakes not to retain personal data for longer than is necessary to ensure compliance with UK DPA, and other statutory requirements.
This means that We will undertake a periodic review of the information held and implement a purge process as required.
We will dispose of any personal data in a way that protects the rights and privacy of the individual concerned. Document control procedures are subject to Policy P006 (Document and Record Control).
Individuals have the right to prevent processing of information while that information is subject to corrective action.
At any time, a person can request to know what information is stored and request action to rectify, block, erase or destroy inaccurate information while that process is underway.
SG Property Ventures will not transfer data to such territories without the explicit consent of the individual. This also applies to publishing information on the Internet – because transfer of data can include placing data on a website that can be accessed from outside the EEA – so We will always seek the consent of individuals before placing any personal data (including photographs) on its website.
Automated individual decision-making (making a decision solely by automated means without any human involvement)
Profiling (automated processing of personal data to evaluate certain things about an individual).
SG Property Ventures Ltd will be the data controller under the terms of the legislation. We are responsible for controlling the use and processing of personal data. The company appoints a Data Protection Officer (DPO) for each site who is available to address any concerns regarding the data held by the company and how it is processed, held, and used.
The Directors are responsible for all day-to-day data protection matters and will be responsible for ensuring that all members of staff and relevant individuals abide by this Policy, and for developing and encouraging good information handling within the company.
The Directors are also responsible for ensuring that the Group Policy is kept up to date. Compliance with the legislation is the personal responsibility of all staff at SGPV who process personal information.
Individuals who provide personal data to the group companies are responsible for ensuring that the information is accurate and up to date.
UK DPA introduces a duty to report certain types of personal data breach to the relevant supervisory authority. SG Property Ventures commit to making all reasonable endeavours to do this within 72 hours of becoming aware of a breach or a suspected breach.
If the breach, or suspected breach, is likely to result in a high risk of adversely affecting individuals’ rights and freedoms, We will take all reasonable steps to inform those individuals.
This Privacy Policy is effective as of 1st October 2024, will be updated from time to time to reflect amendments or developments in UK DPA and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.
We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.
If we make any material changes to this Privacy Policy, we will take all reasonable steps to notify you either through the email address you have provided us, or by placing a prominent notice on our website.
Please view the ICO’s website (https://ico.org.uk) which provides further details and guidance. For help or advice on any data protection or freedom of information issues, please do not hesitate to contact the Data Protection Officer (DPO):
Andrew Godley
SG Property Ventures Ltd
3rd Floor, 86-90 Paul Street
London, EC2A 4NE
