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PRIVACY POLICY
Your privacy is important to us. It is GFSB’s policy to respect your privacy regarding any information we may collect from you across our website, https://www.gfsb.gi/, and other sites we own and operate.
Information we collect
Log data
When you visit our website, our servers may automatically log the standard data provided by your web browser. This data is considered “non-identifying information”, as it does not personally identify you on its own. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.
We may also collect data about the device you are using to access our website. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
Personal information
We may ask for personal information, such as your:
- Name
- Phone/mobile number
- Home/Mailing address
This data is considered “identifying information”, as it can personally identify you. We only request personal information relevant to providing you with a service, and only use it to help provide or improve this service.
How we collect information
We collect information by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used. You are free to refuse our request for this information, with the understanding that we may be unable to provide you with some of your desired services without it.
Use of information
We may use a combination of identifying and non-identifying information to understand who our visitors are, how they use our services, and how we may improve their experience of our website in future. We do not disclose the specifics of this information publicly, but may share aggregated and anonymised versions of this information, for example, in website and customer usage trend reports.
We may use your personal details to contact you with updates about our website and services, along with promotional content that we believe may be of interest to you. If you wish to opt out of receiving promotional content, you can follow the “unsubscribe” instructions provided alongside any promotional correspondence from us.
Data processing and storage
The personal information we collect is stored and processed in the United Kingdom, or where we or our partners, affiliates and third-party providers maintain facilities. We only transfer data within jurisdictions subject to data protection laws that reflect our commitment to protecting the privacy of our users.
We only retain personal information for as long as necessary to provide a service, or to improve our services in future. While we retain this data, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure, and cannot guarantee absolute data security.
If you request your personal information be deleted, or where your personal information becomes no longer relevant to our operations, we will erase it from our system within a reasonable timeframe.
Cookies
We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. Please refer to our Cookie Policy for more information.
Third-party access to information
We use third-party services for:
- Analytics tracking
- User authentication
- Advertising and promotion
- Content marketing
- Email marketing
- Payment processing
These services may access our data solely for the purpose of performing specific tasks on our behalf. We do not share any personally identifying information with them without your explicit consent. We do not give them permission to disclose or use any of our data for any other purpose.
We may, from time to time, allow limited access to our data by external consultants and agencies for the purpose of analysis and service improvement. This access is only permitted for as long as necessary to perform a specific function. We only work with external agencies whose privacy policies align with ours.
We will refuse government and law enforcement requests for data if we believe a request is too broad or unrelated to its stated purpose. However, we may cooperate if we believe the requested information is necessary and appropriate to comply with legal process, to protect our own rights and property, to protect the safety of the public and any person, to prevent a crime, or to prevent what we reasonably believe to be illegal, legally actionable, or unethical activity.
We do not otherwise share or supply personal information to third parties. We do not sell or rent your personal information to marketers or third parties.
Limits of our policy
This privacy policy only covers GFSB‘s own collecting and handling of data. We only work with partners, affiliates and third-party providers whose privacy policies align with ours, however we cannot accept responsibility or liability for their respective privacy practices.
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
Changes to this policy
At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. If you are a registered user on https://www.gfsb.gi/, we will notify you using the contact details saved in your account. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.
Your rights and responsibilities
As our user, you have the right to be informed about how your data is collected and used. You are entitled to know what data we collect about you, and how it is processed. You are entitled to correct and update any personal information about you, and to request this information be deleted. You may amend or remove your account information at any time, using the tools provided in your account control panel.
You are entitled to restrict or object to our use of your data, while retaining the right to use your personal information for your own purposes. You have the right to opt out of data about you being used in decisions based solely on automated processing.
Feel free to contact us if you have any concerns or questions about how we handle your data and personal information.
GFSB Data Controller
Owen Smith
Contact Us
GFSB Data Protection Officer
Gibraltar Regulatory Authority
https://www.gra.gi/
This policy is effective as of 25 May 2023.
GENERAL POLICY
The GFSB adopts to a large measure general policy recommendations of ESBA with some local quirks. Some of our policy on various issues can be found herein, namely:
ENTREPRENEURSHIP
How can we develop a cultural and political context encouraging entrepreneurship?
- Recognise and foster entrepreneurship as a value in education systems
- Neither the EU nor Member States should impose any barriers on self-employment
- Cut red tape, lower the tax burden and reduce administrative costs
- Encourage start-ups, improve access to finance and introduce measures facilitating a restart after bankruptcy
BUSINESS ETHICS
How can ethical business practices be fostered in European economies?
- Develop an EU business ethics policy, in cooperation with NGO’s
- Urgent action to tackle late payments between businesses, unfair contracts and predatory lending
- Exempt SME’s from mandatory corporate social responsibility (CSR) initiatives. The size of many SME’s and their position in society often results in socially responsible behaviour of these companies already. Enforcing mandatory CSR initiatives can have an adverse effect as SME’s often lack the means to comply with specific criteria that are initially designed for large businesses
EDUCATION & TRAINING
How can education and training systems better prepare people for an entrepreneurial career?
- Entrepreneurship should be taught as a horizontal subject at all levels of education
- Education systems should improve entrepreneurial quality by developing links with businesses, encouraging life-long learning, and teaching labour-market relevant skills
GOVERNANCE & ADMINISTRATION
How can administrative bodies facilitate the work of SME’s and avoid burdening them?
- Simplify and clarify all legislation, and reduce administrative burdens
- Involve business stakeholders in drafting, approval, and implementation of all legislation
- Undertake an early, publically available SME Impact Assessments for all new EU legislation and amendments
- Create a pan-European body, composed of SME organisations, to monitor the progress of the EU on SME – relevant issues
FINANCING SMALL BUSINESSES
How can access to finance be improved for small businesses which require
funding?
- A coherent EU policy on business finance must recognise differences in financing micro, small, gazelle, and medium companies
- Simpler and more SME-friendly procedure for applying for EU funding
- Improved access to finance through public-private partnerships, a better venue capital market
- Low interest rates, particularly while the effects of the crisis are still being felt
TAXATION
How can we prevent tax policies from burdening SME’s?
- The EU should encourage Member States to make tax policies more business-friendly
- This can be achieved through non-binding tax incentives and a tax simplification framework to be coordinated
- Lowering of taxes on profits and labour, in order to encourage SME’s to employ new staff
UNFAIR COMPETITION
Unfair competition can manifest itself in various guises such as illegal and unregistered labour, favourable treatment being afforded to some companies over others etc. How can this issue be tackled?
- Governments and institutions must be completely transparent and accountable for its decisions
- A direct and aggressive approach to illegal labour must be employed by the powers that be to address this
- An independent Office for Fair Trading must be established that can carry out arms length investigations into unfair business practices or even complaints from consumers
CODE OF CONDUCT
About the Code of Conduct:
The GFSB Code of Conduct serves as an important resource to ensure our daily business interactions are conducted with integrity. The Code applies and clearly conveys to each of the Board of Directors and GFSB Members that the manner in which we achieve our business results matters.
It is the GFSB’s policy and practice to maintain the highest ethical standards, and to create an organisation that is free of inappropriate or unlawful behavior, and in which all are encouraged to share their concerns without fear of retaliation.
To whom the code applies:
GFSB Members
GFSB recognises that the majority of members join GFSB to avail themselves of the excellent networking opportunities, support, services and benefits available to them as business owners. Having built GFSB to be a brand trusted by business owners and politicians alike, it is imperative that GFSB protects its brand from damage. In order to achieve this, GFSB asks that members and volunteers adhere to a Code of Conduct.
This code is intended to direct the conduct of members in relation to their interaction with other GFSB members, employees and any third parties where the member is perceived to be acting in the name of GFSB or where they or their business purports to be in some way associated with GFSB in addition to being a member.
The code does not extend to the interaction between GFSB members and their customers/clients or any other third party where the GFSB member is not acting in the name/as a representative of the GFSB.
The Code
GFSB asks that members:
- Act and present themselves at all times in a professional and courteous manner to all members, employees and external contacts of GFSB
- Only use the GFSB member logo to signify their membership and not in any way to suggest or imply that the logo represents any trade or professional qualification or standard
- In the case of volunteers, comply with all statutory requirements and GFSB policy and procedure – maintain confidentiality when required to do so and comply with the provisions of the prevailing GFSB data policies
Do not:
- Claim to represent themselves as being approved or endorsed by GFSB in connection with their business activity, or being an approved supplier to GFSB, without having first obtained express written consent from the GFSB Board or appropriate Policy Portfolio Chair
- Proactively market their own business when representing GFSB
- Act towards any employee or member in a manner which may give rise to any claim against GFSB
- Discriminate against any person because of a protected characteristic e.g. age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality and ethnic or national origins), religion or belief, sex or sexual orientation
- Use threatening or abusive behaviour or language
- Make verbal or written statements that are contrary to the aims and objectives of GFSB including policy objectives
- Use GFSB property, resources, equipment or records for any purpose other than the purpose for which they are intended
- Make any undeclared profit, benefit or advantage from being a member or elected officer of GFSB
- Do anything or omit to do anything which is prejudicial to the interests of GFSB or could bring GFSB into disrepute
Board Members
The Code
The board of directors is committed to teamwork and effective decision-making and board members will:
- Represent the broader interests of members and/or stakeholders
- Seek to balance their contributions both as advisors and learners
- Be honest with others and true to themselves
- Refrain from trying to influence other board members outside board meetings that might have the effect of creating factions or divisions thus limiting free and open discussion
- Be willing to be a dissenting voice, endeavour to build on other director’s ideas, offer alternative points of view as options to be considered and invite others to do so too
- On important issues, be balanced in their effort to understand other board members and to make themselves understood
- Once a board decision is made, support the decision even if their own view is a minority one
- Not disclose or discuss differences of opinion on the board with those who are not on the board. The board should communicate externally with “one voice”
- Respect and adhere to the confidentiality of information on sensitive issues, especially government briefings or personal matters
- Be an advocate for the organisation and its mission wherever and whenever the opportunity arises in their own personal and professional networks
- Disclose one’s involvement with other organisations, businesses or individuals where such a relationship might be viewed as a conflict of interest
- Refrain from the use of abusive or offensive language always showing respect for fellow board members and the membership in general
- Conduct GFSB activities so as to fully comply with Gibraltar law
Political Affiliations
GFSB is a non party political organisation and board membership should not be used as a stepping stone for those who have political aspirations. Any board member who joins the executive of any political party should inform the board and step down with immediate effect. Failure to declare such involvement will be seen as a breach of their duties as a board director and they will be asked to step down whilst the board investigates and follows its disciplinary procedure.
Conflict of interest – duty to declare
GFSB, whilst operating in a political environment as a lobbying organisation, maintains an apolitical position, leaving it free to lobby and campaign on behalf of the smaller business community, irrespective of party politics. Members acting on behalf of GFSB have a role in maintaining this political neutrality and high standards of integrity and conduct are expected.
All elected members or volunteers have a duty to declare details, to the satisfaction of the Board any situation where they or an associated person, such as someone with whom they live, a family member or business partner, could have an interest that conflicts or may potentially conflict with the interests of the GFSB.
Examples of what could constitute an ‘interest’ to be declared by Board members are provided below. Please note the list of examples is not exhaustive.
- Brief details, to the satisfaction of the Board of any sales/supplies/services or consultancy provided to GFSB ie where a financial benefit could be received by the member
- Brief details, to the satisfaction of the Board of any sales/supplies/services or consultancy provided to the Government of Gibraltar which could impact the GFSB lobbying objectives
- Brief details, to the satisfaction of the Board of gifts and hospitality received above a cumulative value of £50 in one year in connection with their GFSB volunteer activity
- Details, to the satisfaction of the Board of any election to Public Office, joining any lobby group or the executive of any political party
- Other appointments eg Chamber of Commerce
All Board members should advise the GFSB Chair or Vice Chair of any ongoing interests upon election/appointment or as soon as a relevant interest arises.
Declarations of interest must be included as an item on every formal meeting to ensure that there is no specific conflict or potential for conflict with any items for discussion.
The other board members ie those not declaring an interest, will need to consider the issues (taking advice where appropriate) and decide how to manage the conflict that has been identified:
- It may be decided that there would be no conflict of interest taking into account the particular circumstances.
- Where a conflict is clearly identified, action may include the ‘conflicted’ person either leaving the meeting, not voting on the particular issue or, if relating to a meeting attendance, then ensuring that more than one Board member attends.
The discussion and decision must be recorded in the notes of the meeting.
- The need for such declarations is for openness and transparency – it is not to prevent/forbid business activities outside of the Board members GFSB remit.
Grey Clause: If a Board member is in any doubt that there could be a conflict of interest, the onus is upon that Board member to raise those doubts and disclose the potential conflict of interest and seek clarification from either the Chair or Vice Chair prior to attending the meeting, event or accepting gratuities (maximum of £50.00 per annum).
A failure to declare a conflict of interest will be seen as a breach of their obligations as a board director and they may be asked to step down whilst the board investigates and follows its disciplinary procedure.
Confidentiality
Board members should keep all written and verbal communications and information discussed by the board members confidential unless otherwise agreed upon by the rest of the board. Any breach of confidentiality may result in the board member being asked to step down whilst the board investigates and follows its disciplinary procedure.
Data Protection
GFSB respects the privacy of its employees, members, suppliers and other third parties with whom the GFSB has a business relationship and therefore, commits to handling personal data responsibly and in accordance with all applicable data privacy and data protection laws.
Disciplinary procedure
Any allegations of any breach of this code of conduct including a failure to declare appropriately a conflict of interest will be assessed and determined on the balance of probabilities by a quorum of four members including the Chair by a simple majority vote, in accordance with paragraph 22 of the Constitution. The formal decision will be recorded by the Chair. Such a process should be proportionate to the seriousness of the allegation(s) made.
- A first breach will result in that Board member receiving an informal verbal reminder from the Chair of the GFSB of their obligations under the code of conduct.
- A second breach will result in a formal written warning and any necessary steps to rectify the breach.
- A third breach will result in the Board voting on whether the Board member who has breached the code of conduct should remain on the Board. At this meeting, the Board member concerned will be permitted to make written and verbal submissions and present evidence themselves or can ask another Board member to make representations on their behalf. Formal legal representation will not be permitted.
- Voting will be by ballot and the Board member concerned will be permitted a vote and will be asked to leave the room whilst the vote is conducted. Voting will be In accordance with paragraph 25 of the Constitution. In the case of a tie, the Chair will hold the casting vote.
- Any disputes arising under this procedure will be referred to mediation in the first instance.
If you know of, or have a good reason to suspect, a violation of the Code or other Company policies, you are required to immediately report that information to the Chair or other Officer on the Board