Privacy Notices - Officers’ gifts and hospitality register Privacy Notice


You need to be aware of this notice if you are a member of staff, full or part-time, who is:

  • employed directly by Swindon Borough Council
  • employed on a temporary basis either directly or via an agency
  • employed on a locum basis 
  • employed on a fixed duration contract.
  • employed as an apprentice or trainee.

You also need to be aware of this notice if you are at Swindon Borough Council for work experience or as an intern.

What is a Privacy Notice?

A Privacy Notice is a statement issued by an organisation that explains how the council collects, uses, and shares personal and confidential data about individuals.

Who is collecting and using your personal data?

Swindon Borough Council is the data controller. The data controller decides how your personal data are processed and for what purposes.

Your personal data – what is it?

Personal data relate to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The Data Protection Act 2018 and the General Data Protection Regulation 2016/679 (the “GDPR”) govern data processing.

What personal data do we collect?

We record but do not publish the details of:

  • every gift offered to staff members
  • if that gift is accepted
  • how it is passed on in accordance with the Officer’s Code of Conduct, for example to the Mayor’s Office for the incumbent to donate to his or her designated charities
  • every offer hospitality such as at a sporting or cultural event, the details of the offer and when it was declined
  • every contract in which an officer might have an interest as well as the nature of that interest

However, the data are to be accessible to the public during normal office hours in accordance with legislation.

How do we process your personal data?

We comply with our obligations under the Data Protection Act and the UK GDPR. This means we keep personal data up to date; store and destroy it securely; do not collect or retain excessive amounts of data; protect it from loss, misuse, unauthorised access and disclosure; ensure that appropriate technical measures are in place to protect it.

Why do we need your personal information?

The information is necessary to comply with statutory requirements to promote openness and ensure officials remain impartial. 

How the law allows us to use your information?

Processing is necessary for the performance of a task carried out in the public interest, or in the exercise of official authority vested in the controller.

Relevant legislation includes but is not limited to:

  • Local Government Act 1972
  • Bribery Act 2010
  • Data Protection Act 2018
Who do we share your information with?

The individual declarations may be shared with:

  • members of the public
  • the Press
  • internal Audit and fraud prevention teams
  • the external auditors
How do we protect your information?

The survey is processed via Microsoft Forms, which conforms to the GDPR requirements as of May 2018 (for further information see:Security and Privacy in Microsoft Forms) 

All the raw data is stored securely on Swindon Borough Council’s IT systems, which comply with the Data Protection Act 2018 and UK GDPR.

How long do we keep your personal information?

The information will be retained for two years from the date of receipt of the notification of the gift.

What you can do with your information?

The law gives you a number of rights to control what personal information is used by us and how it is used by us.

You can ask for access to the information we hold on you.

We would normally expect to share what we record about you with you whenever we assess your needs or provide you with services.

However, you also have the right to ask for a copy of all the information we have about you and the services you receive from us. When we receive a request from you in writing, we must give you access to everything we have recorded about you, however, we cannot let you see any parts of your records that contain: 

  • confidential information about other people
  • data a professional thinks will cause serious harm to you or someone else’s physical or mental wellbeing
  • information we think that giving you, may stop us from preventing or detecting a crime
  • personal information that is in both paper and electronic records. If you ask us, we will also let others see your record (except if one of the points above applies)

If you cannot ask for your records in writing, we will make sure there are other ways that you can.

If you have any queries about access to your information contact

You can ask to change information you think is inaccurate

You should let us know if you disagree with something written on your file.

We may not always be able to change or remove that information but we will correct factual inaccuracies and may include your comments in the record to show that you disagree with it.

You can ask to delete information (right to be forgotten).

In some circumstances, you can ask for your personal information to be deleted, for example: 

  • where your personal information is no longer needed for the reason it was collected in the first place
  • where you have removed your consent for us to use your information and where there is no other legal, legitimate or lawful reason for us to keep it
  • where there is no legal reason for the use of your information
  • where deleting the information is a legal requirement
  • where your personal information has been shared with others, we will do what we can to make sure those using your personal information comply with your request for erasure.

Please note that we cannot delete your information where:

  • we are required to have it by law
  • it is used for freedom of expression
  • it is used for public health purposes
  • it is used for, scientific or historical research, or statistical purposes where it would make information unusable
  • it is necessary for legal claims

You can ask us to limit the purpose for which we use your personal data.

You have the right to ask us to restrict what we use your personal information for where:

  • you have identified inaccurate information, and have told us of it
  • we have no legal reason to use that information, but you want us to restrict what we use it for rather than erase the information altogether
  • information is restricted, it cannot be used other than to securely store the data and with your consent to handle legal claims and protect others, or where it is for important public interests of the UK

Where restriction of use has been granted, we will inform you before we carry on using your personal information.

You have the right to ask us to stop using your personal information for any council service. However, if this request is approved this may cause delays or prevent us from delivering that service to you.

Where possible we will always seek to comply with your request, but we may need to hold or use information because we are required to by law.

You can ask to have your information moved to another provider (data portability).

You have the right to ask for your personal information to be given back to you or another service provider of your choice in a commonly used format. This is called data portability.

However, this only applies if we are using your personal information with consent (not if we are required to by law) and if decisions were made by a computer and not a human being. 

It is likely that data portability will not apply to most of the services you receive from the Council. 

You can ask to have any computer made decisions explained to you, and details of how we may have 'profiled' you.

You have the right to question decisions made about you by a computer, unless it’s required for any contract you have entered into, required by law, or you have consented to it.

You also have the right to object if you are being 'profiled'. 'Profiling' is where decisions are made about you based on certain things in your personal information. For example, your health conditions.

If the Council uses your personal information to profile you, in order to deliver the most appropriate service to you, you will be informed.

If you have concerns regarding automated decision-making, or profiling, please contact our Data Protection Officer who will be able to advise you about how we are using your information.

Your right to complain

In the event that you wish to complain about the way that your personal data has been handled by Swindon Borough Council, you should write to the Data Protection Officer and clearly outline your case. Your complaint will then be investigated in accordance with our customer complaint procedure.

If you remain dissatisfied with the way your personal data has been handled, you have the right to complain to the Information Commissioner’s Office at You may refer the matter to the Information Commissioner’s Office whose contact details are below:

Information Commissioner’s Office
Wycliffe House
Water Lane


This website also contains information on data protection and your rights and remedies.

What if you do not provide personal data?

Access to the questionnaire is via an email address. If that is not provided, the data cannot be be submitted. However, the survey does not ask for name or address.

How will we ensure compliance?

The reports are viewed by a panel of Independent Members, none of whom is a councillor.

Any decision-making report for Councillors will be reviewed by the Council’s statutory officers and is open to scrutiny by non-executive Councillors as the general public.

Main privacy notice

You are viewing the Privacy Notice for the Officers’ gifts and hospitality register.

Read the main Privacy Notice