This privacy notice explains how all of the Swire Charitable Trusts collect, use and share personal data, and your rights in relation to the personal data we hold.
We are comprised of the following entities, all with the registered office of Swire House, 59 Buckingham Gate, London, SW1E 6AJ:
- Adrian Swire Charitable Trust (registered charity number 800493);
- John Swire 1989 Charitable Trust (registered charity number 802142);
- Swire Charitable Trust (registered charity number 270726);
- Swire 2765 (registered charity number 1150225); and
- The SCS Trust (registered charity number 1184007).
The term “Swire” (or “we”, “our”, “us”, as applicable) where used in this Notice relates to the particular entity which you are dealing with, and which will be the controller of your personal data under the General Data Protection Regulation and other UK data protection laws.
We may change this Privacy Notice from time to time. This Privacy Notice is effective from 29 August 2018.
How we collect your information
We may collect your personal data in a number of ways, for example:
- From the information that you provide when you complete a grant application or other form;
- When you enter your details on our website (https://www.swirecharitabletrust.org.uk);
- When you communicate with us by post, telephone, fax, email or other forms of electronic communication;
- From information provided to us by your organisation in connection with a grant application or a project which we are supporting;
- From other individuals or organisations seeking to introduce us to you.
The categories of data we collect
We may collect the following categories of personal data about you:
- Your name, job title and contact information such as address, email address and telephone number, such as when you complete our forms or submit information to us;
- Technical information collected through the use of cookies about your use of our website including details of your domain name, location and internet protocol (IP) address, operating system, browser version, the content you view, and how long you stayed on a page (for more information please see our Cookies Policy); and
- Information concerning your engagement with us, including records of communications between you and us.
The basis for processing your data, how we use that data and with whom we share it
1. Legitimate interests
We may process your personal data because it is necessary for our or a third party's legitimate interests. This will always be weighed against your rights, interests and expectations. Our legitimate interests include the operation of Swire in accordance with our respective charitable objects.
Examples of where we process personal data in accordance with our legitimate interests include:
- To correspond with you about our charitable services and activities;
- To evaluate whether your organisation may qualify for a grant;
- Processing technical information about your use of our website to ensure that content on our website is presented in the most effective manner;
- Processing enquiries, complaints and analysing our charitable services;
In this respect, we may also provide your personal data to the following (where this is necessary for our or a third party’s legitimate interests):
- The other Swire charitable entities and initiatives and John Swire & Sons Limited, which provides us with some back-office support;
- Third party service providers who we may engage to assist in delivering grant or other services to you or the organisation you represent;
- Our bank, to whom payment details are provided in order to process a payment made to the organisation you represent;
- Our website operator, who may store details such as name and email address to enable you to use our online grant application forms;
- Our professional advisers, where it is necessary for us to obtain their advice or assistance; and
- Other professionals who assist us, eg website management / IT support.
2. Legal obligations
We may also process your personal data for our compliance with our legal obligations. In this respect, we may use your personal data to comply with subject access requests of others, tax legislation, Charity Commission requirements, for the prevention and detection of crime, and in order to assist the police and other competent authorities with investigations (including criminal investigations). In this respect, we may provide your personal data to our professional advisers, where this is necessary for us to obtain their advice or assistance.
3. Consent
In some circumstances we may seek your specific consent to process your personal data: for example, if we wish to put you in touch with other funders and external agencies and/or representatives of other grant recipients.
If you have given your consent and you wish to withdraw it, please contact us using the contact details below. Please note that where our processing of your personal data does not rely on your consent, we may not be able to fulfill your request (please see ‘Your Rights’ below).
Retention of your data
We may retain your personal data for as long as is necessary to deliver our charitable services to the organisation you represent, and to protect our legal interests (for example where required by relevant authorities, or for a reasonable legal limitation period after we have ceased providing grant funding to the organisation you represent/ed) or as otherwise stated to you when your data is collected, or for such period as we reasonable consider appropriate in connection with our relationship with you and/or the organisation you represent/ed; or for record-keeping and archival purposes.
International transfers
As a matter of course, we do not transfer your personal data outside the European Economic Area (EEA). We may, however, transfer your personal data around the world on an ad hoc basis. In such circumstances, we will consider whether any additional measures are required in order to give adequate protection for the information when it is transferred outside of the EEA.
Your rights
- To be informed what personal data we hold about you and/or to obtain access to it (i.e. by receiving a copy of it in a permanent form);
- To require us to correct the personal data we hold about you if it is inaccurate;
- To require us (in certain circumstances) to erase your personal data;
- To request that we restrict our data processing activities (and, where our processing is based on your consent, you may withdraw that consent, without affecting the lawfulness of our processing based on consent before its withdrawal);
- To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
- To object, on grounds relating to your particular situation, to any of our particular processing activities where you feel this has a disproportionate impact on your rights.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply: for example, if we have reason to believe the personal data we hold is accurate or we can show our processing is necessary for a lawful purpose set out in this Privacy Notice.
You can find out more about your rights under data protection legislation at www.ico.org.uk.
Questions and concerns
If you have any questions or concerns about how we process your personal data, or you wish to exercise any of the rights set out above, you may contact:
If you are not satisfied with how we are processing your personal data, you can raise a concern with the Information Commissioner (www.ico.org.uk).