Property advisers to HM Government of Gibraltar




Land Property Services Limited (“LPS”) is Gibraltar’s largest firm of Chartered Surveyors. A private company, LPS is contracted by Her Majesty’s Government of Gibraltar (“HMGoG”) to act as it agents in all land-related matters; to this end, the company works exclusively for HMGoG.

Regulated by the Royal Institution of Chartered Surveyors, the company boasts some of the most highly-respected property professionals in Gibraltar, with dedicated teams serving a vast portfolio of property-related functions on behalf of HMGoG. These functions include (but are not limited to):

1.  The sale of land and properties, both residential and commercial;

2.  Collection of rent, rates and service charges in respect of certain properties owned by HMGoG;

3.  Maintaining the Land Titles Register and collecting payment of Stamp Duty;

4.  Valuations of residential and commercial properties;

5.  Managing HMGoG’s commercial estates;

6.  Maintaining the Register of Business Tenancies;

7.  Maintaining the Register or Residential Occupation.


On 25th May 2018, new legislation regarding data protection, the General Data Protection Regulations (GDPR), came into effect in all countries forming part of the European Union. The GDPR defines how companies have to handle the personal data and privacy of individuals within the EU from now on.

At LPS, we have always ensured that any data that we collect as agents for HMGoG is held in the strictest of confidence. Even so, we have had to carry out a few changes to our privacy policies in order to be fully compliant with the GDPR.

To carry out our functions on behalf of HMGoG and provide services to our customers, we need to use information which may be personal or private. For example, we may need to know a customer’s name and address, contact details (e.g., telephone numbers, email addresses), and how customers would like to make payment to HMGoG through us.

As we do this, we would like you to take some time to read this privacy statement. It will explain what information we might collect about you, why we collect it, what we may use it for, and who we may give it to. We will also explain your rights towards your information and how we look after is whilst we have it.


The information we collect about you will vary based on the service we are providing. Typically, we need details such as:

·  Your name and address (so we know who you are and what service you need from us);

·  Your contact details, such as home and/or mobile telephone numbers and email addresses (so that we can contact you in relation to the service that is being provided);

·  Your bank account or other financial details (so we can manage your payment for our services).

We only collect information about you that we need to ensure that we provide the best possible service to you. We respect your privacy and we try to minimise what we do collect.


We prefer to collect the information we need directly from you. That way, you are in control of the information that we receive, and we can be sure that we receive the most accurate and up-to-date information. We will usually do this:

·  When you set up an account with us for the payment of rent, rates and/or service charges;

·  When you submit a deed for registration;

·  When you purchase or rent a property from HMGoG through us;

·  When you submit a tender application for the purchase or rental of a property;

·  When you or your lawyer request consent to the sale of a property ultimately belonging to HMGoG;

·  If you submit an enquiry by email via our website;


We use your information in various ways depending on the function it has been collected for. These include, but might not be limited to:

·  Verifying your identity when entering into legal documentation with HMGoG;

·  Meeting the purposes that you provided your information for;

·  Providing you with the services you want;

·  Administering your account;

·  Preventing fraud;

·  Keeping our records accurate and up-to-date;

·  Creating statistical information, market research and analysis to better manage and run our business;

·  Comply with any legal obligations we may have.


We appreciate that you have provided your information to us and may not want us to share it with other people or organisations, however sometimes it is necessary for us to do so.

We only share your information where we are permitted or required to by law, or where you have requested us to do so. For example, we may share your information with:

·  Any relevant HMGOG department, HMGOG-owned company or HMGOG authority where there is a legitimate requirement for your information to be shared (particularly where LPS is carrying out state functions as agents for HMGoG). This includes, but is not limited to:

o  The Housing Department;

o  The Income Tax Department;

o  The Treasury Department;

o  The Education Department;

o  The Technical Services Department;

o  The Department of Town Planning and Building Control;

o  The Department of the Environment and Climate Change;

o  The Civil Status and Registration Office;

o  The Central Arrears Unit;

o  Gibraltar Cultural Services;

o  Gibraltar Health Authority;

o  Gibraltar Car Parks Limited;

o  Gibraltar Residential Properties Limited;

o  Gibraltar Land (Holdings) Limited;

o  Gibraltar Commercial Property Limited;

o  The Gibraltar Parliament;

o  Royal Gibraltar Police;

o  Gibraltar Financial Intelligence Unit;

o  Gibraltar Co-Ordinating Centre for Criminal Intelligence and Drugs;

o  Gibraltar Electricity Authority;

o  AquaGib Limited;

o  Gibtelecom;

o  Royal Gibraltar Post Office.

·  Any of your family, associates, or someone who represents you and where you have asked us to do so;

·  Our employees who provide you with our services and who carry out the above-mentioned functions;

·  Carefully selected contractors and specialists to help us provide you with our services;

·  External agencies like the police, ambulance and fire service in the event of an emergency;

·  Any person or organisation where we are required to because of a Court order, legal duty or statutory obligation.

We are careful to minimise the sharing of your information and will only do so when it is absolutely necessary, or when we have specific authority to do so. Whenever we share your information we do everything we can to ensure it is protected from misuse or loss.


When we use information about you we take all reasonable efforts to do so fairly and lawfully. We think it is likely that our customers know we use information about them, and we provide notices of such wherever we can.

We never use information about you unless it is lawful for us to do so and we have a clearly defined need or purpose.

When we collect information about you we ensure that we minimise what we collect. We try to collect enough accurate and up-to-date information to ensure we provide you with the excellent, efficient customer service you deserve and no more. We try not to keep your information for longer than we need it and we ensure that the records we have about you are managed properly and deleted promptly and securely when we no longer need them.

We make every effort to ensure your rights towards your information, which we detail below.

We take appropriate care to secure the information we hold about you. We also have policies and procedures to ensure your information is only available to our employees who need to see it to do their job, and we train those employees appropriately.

In everything we do with your information we try to be fair, lawful, and open, and we take seriously our obligations towards your privacy and the protection of information we may hold about you

On our website

When visiting our website, you may also be providing us with certain information via our use of website ‘cookies’. You can find out more about this by reading the Cookie Statement on our website (

When you enter data onto secure areas of our websites, a Secure Socket Layer (SSL) is initiated. A SSL is a security device which ensures that any data which you enter is encrypted during transmission over the internet. Encryption means the data is encoded so that it is not legible until such time as we decode it.

No data transmission over the internet can ever be entirely secure. While we do our best to protect your personal information, we cannot guarantee its security and you must be aware of this when using our websites.

Our websites may contain links to other websites. If you follow a link to any of these websites, please note that these websites have their own Terms & Conditions and privacy policies and that we cannot accept responsibility for their content. This privacy statement applies only to our website.

By email and phone

If you have contacted us by email, or provided an email address, we may use that to contact you if we need to.

You should also be aware that information conveyed by email could be deliberately or accidentally intercepted or corrupted. Whilst we make every effort to ensure that emails we send to you are free from viruses this cannot be guaranteed. We recommend that you scan all email for viruses with appropriate and frequently updated virus checking software.

If you have given us you phone number (landline or mobile), we may use it to contact you if we need to, including sending texts. If you call our customer contact line, we also record your phone call, for security and training purposes, and to ensure we record the details of your contact.

Please let us know if your mobile phone number or email address changes so that we can keep this information up to date.


You have certain rights under data protection laws in relation to your personal data. You have the right to:

·  Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you. If you require this, then please reach out to our Data Protection Officer (“DPO”) on the contact details found below.

·  Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please contact the relevant department at LPS and our employees will assist you as required. If you are unsure of which department you need to contact, please reach out to our DPO on the contact details found below.

·  Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with legislation. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

·  Object to processing of your personal data. This is in situations where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights. Please note that if you object to the processing of certain data then we may not be able to provide our full range of services.

·  Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

o  if you want us to establish the data's accuracy;

o  where our use of the data is unlawful but you do not want us to erase it;

o  where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

o  you have objected to our use of your data but we need to verify whether we have overriding legitimate or legal grounds to use it.

Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to provide the full range of our services to you.

·  Request the transfer of your personal data to you or to a third party. We will provide you with your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. If you require this then please reach out to our DPO on the contact details found below.

·  Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide you with the services you require. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We may also ask that you attend a meeting with our DPO (or other suitably-trained employee) to jointly complete a questionnaire for you to provide further information in relation to your request and speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you fail to provide personal data

Where we need to collect personal data to carry out statutory functions on behalf of HMGoG, and you fail to provide that data when requested, we may not be able to provide you with the services you require.


The GDPR introduces a duty on all companies to appoint a Data Protection Officer. The DPO has a number of important responsibilities, including:

·  monitoring LPS' compliance with the GDPR and other data protection laws;

·  raising awareness of data protection issues, training LPS staff and conducting internal audits; and

·  cooperating with supervisory authorities, such as the Gibraltar Regulatory Authority.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO by email on

Last updated: 17/10/2019