Legal

TFT Modern Slavery Statement

Tuffin Ferraby Taylor (TFT) Ltd fully endorses the Modern Slavery Act 2015 and the Senior Directors and Senior Management team is committed, by providing adequate resources and training etc. across the business, to ensuring the firm operates a zero-tolerance approach to forced labour, slavery or human trafficking within our organisation or in any part of our supply chain.

TFT operates a number of internal policies to ensure that business is conducted in an ethical and transparent manner, these policies include:

• Recruitment Policy
• Core Standards of Behaviour Policy
• Ethical Policy
• Training & Development Policy

TFT takes its responsibility towards all employees, including investment in opportunities and knowledge development for undergraduates, graduates, traineeships, apprentices and their equivalents, and in ethical conduct of relationships with business associates and the extended community, and will continue to support environmental, economic and social progress.  TFT was early adopter of flexibility to enable the widest participation in development and professional career opportunities.

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Anti-slavery and human trafficking policy

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels. Senior Directors, agency workers, seconded workers, volunteers, agents, contractors and suppliers.

Tuffin Ferraby Taylor (TFT) Ltd strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

Modern Slavery and Human Trafficking

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Commitments

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

1. We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
2. The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the
3. responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
4. We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
5. We take a risk based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach we will also assess the merits of writing to suppliers requiring them to comply with our standards required to combat modern slavery and trafficking.
6. Consistent with our risk based approach we may require:
7. employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance
8. Suppliers engaging workers through a third party to obtain that third parties’ agreement to be compliant
9. As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance.
10. If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach.

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Website terms and conditions

Acceptance

These terms and conditions apply to the entire contents of this website and to the contents of any e-mail correspondence between Tuffin Ferraby Taylor (TFT) Ltd (‘TFT’/”we/”us”) and you made via this website or in respect of any comment or enquiry you make via this website. Please read these terms and conditions carefully before using this website.

By accessing and/or using this website you agree to be bound by these terms and conditions and our privacy policy (see below). If you do not accept these terms, do not continue to use or access this website and leave this website immediately.

We may revise these terms and conditions at any time by updating this posting. You should check this posting every time you access this website to review the then current terms and conditions because you will be legally bound by those revised terms and conditions.

Disclaimer of endorsement

This website may include hypertext links or other links, references or other information relating to the products, services or views of third parties. None of these constitute or imply TFT’s endorsement, sponsorship or recommendation of those third parties or their products, services, websites or views.

Intellectual property rights

The copyright, trade mark rights and other intellectual property rights in all material on this website or contained within downloads available from this website (including without limitation text, photographs, graphical images, trademarks and logos) are owned by TFT or its licensors.

You are permitted to download, store and print this website and downloads available from this website (or part thereof) only for your own private and non-commercial use or the private and non-commercial use of your firm or company provided that:

• you must not modify, alter or translate such original material;
• you must not use, reproduce, publicly display, distribute or use such material or any part of it for any public or commercial purposes without the express prior written permission of TFT;
• you must not use any graphics contained within such material separately from accompanying text; and
• you must retain all copyright, trade mark and other similar proprietary notices contained in the original materials on all copies of the material.

Subject to the above, no part of this website or any download made available on this website may be reproduced, downloaded or stored in any other website or included in any public or private electronic retrieval system or service without TFT’s prior written permission.

Linking

If you would like to link to this website from your website, you may only do so on the basis that you link to, but do not replicate, the home page of this website, and subject to the following conditions:

• you do not remove, distort or otherwise alter the size or appearance of the any trade marks or logos appearing on this website;
• you do not create a frame or any other browser or border environment around this website or any form of link that disguises the URL of, and/or bypasses the homepage of, this website;
• you do not in any way imply that TFT is in any way endorsing any products or services other than its own;
• you do not misrepresent your relationship with TFT nor present any other false information about TFT;
• you do not otherwise use (whether as or as part of any branded link or otherwise) the name “Tuffin Ferraby Taylor (TFT) Ltd” or any associated trade marks or logos displayed on this website;
• your website does not contain content that is distasteful, defamatory, offensive or controversial, infringes any intellectual property rights or other rights of any other person or otherwise does not comply with all applicable laws and regulations;
• you will immediately remove and cease to operate such links upon TFT’s request, which shall be at TFT’s sole discretion; and
• you shall fully indemnify TFT for any loss or damage suffered by TFT for your breach of any of the above conditions.

Changes and access to website

While TFT has used reasonable efforts to ensure that the information on this website is correct, such information may include technical inaccuracies and/or typographical errors. TFT does not warrant the accuracy and completeness of the material on this website or any download available from this website. TFT may make changes to the material on this website, or to the products, services and prices described in it, at any time without notice. The material on this website may be out of date, and TFT makes no commitment to update such material.

TFT may at its sole discretion change, remove, or suspend access to, the website or any part of it without notice to you.

Viruses and bugs

Whilst TFT has endeavoured to ensure that downloads from this website are free from viruses, bugs, worms and malicious or disruptive codes, TFT cannot guarantee that this is the case. You must ensure that you take appropriate measures and utilise anti-virus software to protect your information technology systems from the foregoing.

Disclaimers

This website, and its contents, is provided on an ‘as is’ and ‘as available’ basis, without any conditions, warranties, representations, guarantees or other terms whatsoever, whether express or implied, including without limitation any warranty of accuracy, completeness, quality, satisfactory quality, merchantability, fitness for a particular purpose or non-infringement of third party rights, and all of the foregoing are hereby excluded to the fullest extent permitted by law. No oral or written information or advice provided by us in response to any comment or enquiry made by you via this website shall create any term, condition, warranty, formal offer of goods or services or legally binding contract, nor shall you or any other person rely on any such information or advice.

Exclusion of liability

You, as a user of this website, shall assume all responsibility and risk for your use of this website and TFT accepts no responsibility and shall not be liable for any losses (including without limitation indirect, direct, consequential, incidental, special, exemplary or punitive damages of any kind, loss of profits, loss of or damage to data or information technology hardware or software) arising from your use, or otherwise connected with, this website including without limitation any such losses resulting from:

• your, or any other person’s, use or reliance on this website or download available from this website or information contained therein, any link to a third party website (or the contents of that website) contained on this website or any response to any comment or enquiry made by you via this website; or
• any errors, omission or inaccuracies of or in any information or material contained in this website or any download available from this website; or
• any interruption or suspension of access to, your inability to use, or any change, alteration or removal of, this website or any download available from this website or any link to any third party websites contained on this website; or
• any virus, bug, worm or malicious or disruptive code which may access your information technology systems, or unauthorised access to your information technology systems, resulting from your use, storage or downloading of this website or any download available from this website, including without limitation loss or deletion of, or damage to, data or files or such systems.

Nothing in these terms and conditions shall exclude or limit TFT’s liability for death or personal injury caused by negligence, fraud or any liability which cannot be excluded or limited under applicable law.

Law and jurisdiction

These terms and conditions and any dispute arising in any way in relation to this website will be governed by and construed in accordance with the laws of England. You irrevocably submit to the exclusive jurisdiction of the English courts.

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Privacy policy

Tuffin Ferraby Taylor (TFT) Ltd (‘TFT’/”we”/”us”) believe that internet privacy is important and that any personal information collected by us from you should be dealt with responsibly.

Please read the following privacy policy to understand how we use and protect the personal information that you provide to us.

Any changes to our privacy policy in the future will be posted to this website and, where appropriate, through e-mail notification.

Tuffin Ferraby Taylor (TFT) Ltd is committed to protecting and respecting any personal information you share with us.

This statement describes what types of information we collect from you, how it is used by us, whether we share it with others, how you can manage the information we hold and how you can contact us.

We will always give you the option not to receive marketing communications from us. We will never send you unsolicited ‘junk’ email or communications; or share your data with anyone else who might.

The contents of this statement may change from time-to-time so you may wish to check this page occasionally to ensure you are still happy to share your information with us. Where possible, we will also contact you directly to notify you of these changes.

What information do we collect?

We collect information about you and your requirements when you connect with a TFT colleague, engage with our website, with our communications or attend an event. We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.

Where you engage with us in a business context, we may collect the following information:

• name and job title
• contact information including email address
• demographic information such as postcode, preferences and interests
• information about your computer and about your visits to and use of the TFT website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation)
• any other information that you choose to send to us

Because our website has Google Analytics, our website uses cookies. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

How do we use this information?

TFT will only process information that is necessary for the purpose for which it has been collected. You will always have the option not to receive marketing communications from us (and you can withdraw your consent or object at any time). We will never send you unsolicited ‘junk’ email or share your personal information with anyone else who might.

There are various ways in which we may use or process your personal information. We list these below:

Consent

Where you have provided your consent, we may use and process your information to contact you from time to time about events, service line activities or information which we think may be of interest to you.

You can withdraw your consent at any time by contacting us on the details provided within the ‘How can I manage the information we hold about you’ section below or, in relation to any marketing messages you receive, by using the unsubscribe option included in those messages.

Contractual performance

We may use and process your personal information where this is necessary to perform a contract with you and to fulfil and complete your instructions and other transactions entered into with us.

Legitimate interests

We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.

Processing necessary for us to respond to understanding customers’ needs

To undertake market analysis and research (including contacting you with client surveys) so that we can better understand you as a client and provide tailored information that we think you will be interested in. We will only send marketing communications to you if you have provided your consent for us to do so or which we have obtained in the ways mentioned in the paragraphs above.

Processing necessary for us to promote our business, brands and services and measure the reach and effectiveness of our campaigns

1. To send you marketing information from time to time after you have made an enquiry. We will only contact you with information about our own services (and in ways the law allows), which we believe to be relevant and informative. You have the right to object to us sending you this information at any time.
2. To contact you with targeted messages delivered online through social media and other platforms operated by other companies, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the platforms on which you receive advertising from us.
3. To identify and record when you have received, opened or engaged with our website or electronic communications.

Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively

1. To verify the accuracy of information that we hold about you and create a better understanding of you as a client.
2. For network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access;
3. To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
4. To inform you of updates to our terms and conditions and policies.

How do we share this information?

We do not sell, distribute, lease or share your information with any third parties.

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.

How long do we keep your information for?

We will not hold your personal information in an identifiable format for any longer than is necessary. If you are a client or otherwise have a relationship with us we will hold personal information about you for a longer period than if we have obtained your details in connection with a prospective relationship.

If we have a relationship with you, we hold your personal information to comply with legal requirements. We hold your personal information for this period to establish, bring or defend legal claims.

You exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law.

How can I manage the information we hold about you?

You have the right as an individual to access your personal information we hold about you and make corrections if necessary. You also have the right to withdraw any consent you have previously provided and ask us to erase information we hold about you.

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.

You have the right to:

1. Ask for a copy of the information that we hold about you.
2. Withdraw your consent (where we rely on it).
3. Object to our use of your information (where we rely on our legitimate interests to use your personal information) provided we do not have any continuing lawful reason to continue to use and process the information. When we do rely on our legitimate interests to use your personal information for direct marketing, we will always comply with your right to object.
4. Erase your information (or restrict the use of it), provided we do not have any continuing lawful reason to continue to use and process that information.

You can exercise the above rights and/or manage your information by contacting us using the details below:

Post: Operations Director, Tuffin Ferraby Taylor (TFT) Ltd, Ground Floor, The Spaces Building, Station View, Guildford, GU1 4AR

Email: Operations@tftconsultants.com

Phone: 0203 479 7777

If you have any specific data protection concerns or a complaint, you can address it to: The Operations Director, Tuffin Ferraby Taylor (TFT) Ltd, Ground Floor, The Spaces Building, Station View, Guildford, GU1 4AR

If you are unhappy, you have the right to lodge a complaint with a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed. The contact details for the Information Commissioner’s Office, the data protection regulator in the UK, are below:

Post:  Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Call:   0303 123 1113

Email:  casework@ico.org.uk

Cookies

‘Cookies’, which are small text files that are placed on your computer when you first visit the site, are used on this website. Cookies make it easier for you to log on to and use this website during future visits. They also allow us to monitor website traffic and to personalise the content of this website for you. Most browsers now recognise when a cookie is offered and permit you to refuse or accept it, although if you refuse to accept cookies you may not be able to use certain features of this website.

Contact

All comments, queries and requests relating to TFT’s use of your personal information are welcomed and should be addressed to lgunn@tftconsultants.com.

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