Family Office Privacy Notice

The Grosvenor Estate strongly believes in protecting your privacy and the confidentiality of your personal information. In order to explain how the Grosvenor Estate collects, uses and protects personal information we have developed the following privacy notice.

'We' and 'Us' means The 4th Duke of Westminster's 1964 Settlement Trust. We are the data controller for the purposes of the Data Protection Act 2018 and the UK General Data Protection Regulation (GDPR).

You can contact us with any questions you may have about privacy and/or data protection. Our contact details are as follows

Post:

Information Governance Manager, Eaton Estate Office, Eccleston, Chester, Cheshire, CH4 9ET

Email:

Data.protectionFIO@grosvenor.com

About this Privacy Notice

This privacy notice covers the following:

Accidents and incidents
Boat trips on the Reay Forest Estate
Contractors and suppliers of services
Events held on the Abbeystead Estate, Eaton Estate or Reay Forest Estate
Holiday accommodation on the Reay Forest Estate
Management of the natural environment on the Abbeystead Estate, Eaton Estate or Reay Forest Estate
Sales of produce (i.e. venison and logs) and services (i.e. arboriculture and landscaping)
Security activities, including CCTV, use of dashboard cameras, use of body worn cameras, use of two-way radios and automatic number plate recognition
Sporting activities (including fishing, stalking and shooting)
Supporting the local community on the Abbeystead Estate, Eaton Estate or Reay Forest Estate
Unsolicited correspondence
Visitors to the Abbeystead Estate, Eaton Estate or Reay Forest Estate

We explain in detail below the types of information that we collect, how and why we use that information, and what rights you have in connection with your personal information.

We must have a lawful basis to process your personal information, and this notice explains what our lawful basis is in respect of each purpose for which we may keep and use information about you. Generally, we are allowed to process your personal information where it is necessary in connection with a contract between us, where it is necessary in order for us to comply with our legal obligations, or where we have a legitimate interest to do so (but we will always consider whether your right to privacy overrides our interest).

We may keep certain, limited information about you for our historical records, on the basis that there is a public interest in our doing so. Occasionally, we may also use your personal information on the basis that you have given us consent to do so. You can find more information about our historical records, and the instances where we will require your consent, below.

What information do we collect about you and how do we collect it?

We may require you to provide certain personal information to us where it is necessary. If you fail to provide certain information when requested, we may not be able to offer you a specific service or perform the contract with you.

We may collect additional personal information as required.

Information you provide to us

We may collect and use the following information about you:

Identification and contact information, such as your full name, date of birth, age, postal address, email address and telephone number(s)
Information about your employment, including your job title, the organisation for whom you work
Insurance certificates
A copy of your identification documents (driving licence or birth certificate for example)
Financial information, such as your bank account details, unique tax reference number
More sensitive information about you including health information

Information about children

We may collect and use the following information about children in relation to the following:

Accidents and incidents
Boat trips on the Reay Forest Estate
Events held on the Abbeystead Estate, Eaton Estate or Reay Forest Estate
Holiday accommodation on the Reay Forest Estate
Security activities, including CCTV, use of dashboard cameras, use of body worn cameras, and automatic number plate recognition
Visitors to the Abbeystead Estate, Eaton Estate or Reay Forest Estate
Work experience

Information we collect about you from other sources

We may collect information about you from other sources. This may include the following:

The Travel Chapter Limited trading as Holidaycottages.co.uk and CKD Galbraith LLP (company number SO300208) in relation to boat trips, holiday accommodation and sporting activities undertaken on the Reay Forest Estate
Information you have shared publicly, including on social media
Information provided to us in relation to your health, if an accident and/or incident has taken place (see ‘Personal information concerning health’ below)
Information provided to us in relation to events taking place on the Abbeystead Estate, Eaton Estate or Reay Forest Estate
Information to determine if you are VAT registered

This list is not exhaustive and, in specific instances, we may need to collect additional personal information for the purposes set out in this notice.

How do we use your personal information?

We take data protection law seriously. We have set out in the table below how and why we use your information, and what our legal basis is to be able to use your information in each way. The principal legal bases on which we use your information are as follows: (a) to Allow us to enter into and perform a contract, (b) to enable us to comply with legal obligations, and (c) in order to pursue legitimate interests of our own or those of third parties (provided your interests and fundamental rights do not override those interests).

Specific area where we may be required to process personal information	Basis for processing information	Allow us to enter into and perform a contract	Enable us to comply with legal obligations	In order to pursue legitimate interests of our own or those of third parties (provided your interests and fundamental rights do not override those interests)
Accidents and incidents Boat trips on the Reay Forest Estate Contractors and suppliers of services Events held on the Abbeystead Estate, Eaton Estate or Reay Forest Estate Holiday accommodation on the Reay Forest Estate Security activities, including CCTV, use of dashboard cameras, use of body worn cameras, use of two-way radios and automatic number plate recognition Sporting activities (including fishing, stalking and shooting) Visitors to the Abbeystead Estate, Eaton Estate or Reay Forest Estate Work experience	Complying with our health and safety obligations		X	X
Supporting the local community on the Abbeystead Estate, Eaton Estate or Reay Forest Estate	If you are involved with community activities, have a role within the community or are applying for a specific role			X
Boat trips on the Reay Forest Estate Contractors and suppliers of services Events held on the Abbeystead Estate, Eaton Estate or Reay Forest Estate Holiday accommodation on the Reay Forest Estate Sales of produce (i.e. venison and logs) and services (i.e. arboriculture and landscaping) Sporting activities (including fishing, stalking and shooting) Visitors to the Abbeystead Estate, Eaton Estate or Reay Forest Estate	Dealing with any complaints you may have			X
Accidents and incidents Boat trips on the Reay Forest Estate Contractors and suppliers of services Events held on the Abbeystead Estate, Eaton Estate or Reay Forest Estate Holiday accommodation on the Reay Forest Estate Sales of produce (i.e. venison and logs) and services (i.e. arboriculture and landscaping) Security activities, including CCTV, use of dashboard cameras, use of body worn cameras, use of two-way radios and automatic number plate recognition Sporting activities (including fishing, stalking and shooting) Visitors to the Abbeystead Estate, Eaton Estate or Reay Forest Estate	Dealing with any legal disputes involving you		X	X
Management of the natural environment on the Abbeystead Estate, Eaton Estate or Reay Forest Estate	If you support us in managing the natural environment on the Abbeystead Estate, Eaton Estate or Reay Forest Estate			X
Contractors and suppliers of services	To determine whether you are able to provide goods and/or services to the Grosvenor Estate	X	X	X
Security activities, including CCTV, use of dashboard cameras, use of body worn cameras, use of two-way radios and automatic number plate recognition	To ensure the security of the Grosvenor Estate, including preventing unauthorised access to any area of the Grosvenor Estate		X	X
Contractors and suppliers of services	To detect and prevent fraud, money-laundering and other crimes		X
Events held on the Abbeystead Estate, Eaton Estate or Reay Forest Estate	To determine if you and/or the organisation you represent are able to hold an event on the Abbeystead Estate, Eaton Estate or Reay Forest Estate			X
Contractors and suppliers of services	To enable you to provide goods and/or services to the Grosvenor Estate	X		X
Unsolicited correspondence	To interact and respond to any communications you send us, including social media posts that you tag us in			X
Contractors and suppliers of services Supporting the local community on the Abbeystead Estate, Eaton Estate or Reay Forest Estate	To let you know about any important changes to our business or policies			X
Events held on the Abbeystead Estate, Eaton Estate or Reay Forest Estate Visitors to the Abbeystead Estate, Eaton Estate or Reay Forest Estate	To manage events for you and/or the benefit of the organisation that you represent on the Abbeystead Estate, Eaton Estate or Reay Forest Estate		X	X
Boat trips on the Reay Forest Estate Contractors and suppliers of services Events held on the Abbeystead Estate, Eaton Estate or Reay Forest Estate Holiday accommodation on the Reay Forest Estate Sales of produce (i.e. venison and logs) and services (i.e. arboriculture and landscaping) Security activities, including CCTV, use of dashboard cameras, use of body worn cameras, use of two-way radios and automatic number plate recognition Sporting activities (including fishing, stalking and shooting) Supporting the local community on the Abbeystead Estate, Eaton Estate or Reay Forest Estate Visitors to the Abbeystead Estate, Eaton Estate or Reay Forest Estate	To review and improve the performance of our systems, processes and employees (including training)			X
Sales of produce (i.e. venison and logs) and services (i.e. arboriculture and landscaping)	To sell and deliver produce		X	X
Holiday accommodation on the Reay Forest Estate	To provide you with holiday accommodation on the Reay Forest Estate			X
Sporting activities (including fishing, stalking and shooting)	To enable you to undertake sporting and other related activities	X	X	X
Accidents and incidents Contractors and suppliers of services Holiday accommodation on the Reay Forest Estate Sporting activities (including fishing, stalking and shooting Visitors to the Abbeystead Estate, Eaton Estate or Reay Forest Estate	Verifying your identity		X	X
Work experience	To enable you or a child to undertake work experience		X	X

Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Personal information concerning health

Personal information concerning health requires higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information in the following circumstances:

In limited circumstances, with your explicit written consent
Where we need to carry out our legal obligations and in line with this privacy notice
Where it is needed to assess any special requirements you may have due to any disabilities or health issues, subject to appropriate confidentiality safeguards

Less commonly, we may process this type of personal information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

We do not need your consent if we use personal information concerning health in accordance with this privacy notice to carry out our legal obligations, or exercise specific rights. In limited circumstances, we may require your written consent to allow us to process certain health information. If we do, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. Where we process such information it shall be in accordance with this privacy notice and subject to appropriate safeguards.

Information about accidents and incidents

If you have an accident and/or are involved in an incident, the legal basis of processing your personal information may also including protecting your vital interests.

Who do we share your personal information with?

Sharing your information within the Grosvenor Estate

We may share your information with our employees where this is necessary, such as for internal administration purposes. Your information will only be shared with such employees as are reasonably necessary for these purposes.

Sharing your information with third parties

We may need to share your personal information with certain third parties, including third-party service providers. We require third parties to respect the security of your personal information and to treat it in accordance with the law.

We will share your personal information with third parties where it is necessary to administer any contracts with you or where we have another legitimate interest in doing so. The following activities are carried out by third-party service providers:

Delivering logs
Managing our CCTV, body worn camera and automatic number plate recognition equipment
Payment into supplier's bank accounts

There are also certain exceptional circumstances in which we may disclose your information to third parties. This would be where we believe that the disclosure is:

Required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings
Debt collection and tracing agencies
Necessary to protect the safety of our employees, our property or the public
Necessary for the prevention or detection of crime, including exchanging information with other companies or organisations for the purposes of fraud protection and credit risk reduction.

Our Finance management IT system is provided by MRI Software Limited (company number 03341304). We may allow MRI Software Limited to access your personal information where it is necessary in order for them to provide this service. This may include preventing or addressing service or technical problems, and dealing with support issues.

Our visitor management system is provided by Valto IT Limited. We may allow Valto IT Limited (Company number 10625574) to access your personal information where it is necessary in order for them to provide this service. This may include preventing or addressing service or technical problems, and dealing with support issues.

If you hold an event at the Eaton Estate your details may be held in a customer relationship management system, operated by Salesforce held in both the European Union (EU) and the USA. Some information will therefore be transferred outside the European Economic Area (EEA). The sharing of this information is necessary in order for us to provide a service to you (namely, to enable you to hold an event at the Eaton Estate).

The senior management of the Reay Forest is undertaken on the Grosvenor Estate’s behalf by CKD Galbraith LLP (company number SO300208). We may therefore share your personal information with CKD Galbraith LLP in relation to any personal information processed at the Reay Forest Estate

Sharing your information with the general public

We will not make any information concerning you available to the public, except in the case of our historical records (please see ‘How long do we keep your personal information’ below). These records will be stored securely and confidentially for a period of 100 years before being made available to the public.

How long do we keep your personal information?

Specific area	Retention period
Accidents and incidents	40 years after date of accident or incident
Boat trips on the Reay Forest Estate	1 calendar year after boat trip
Contractors and suppliers of services	Company name, address and VAT number will be held permanently invoices: 6 financial years All other information will be kept for 2 financial years from the date of the last transaction for companies we no longer use.
Events held on the Abbeystead Estate, Eaton Estate or Reay Forest Estate	Application for events that are unsuccessful: 1 year from date of application Key contacts for events: 6 years If you provide us with your personal information in relation to an event and you then leave that organisation, we will then remove your contact details from our customer relationship management system and replace them with another contact when you or your organisation inform us of the change. Names included within information provided to support an event, for example a caterer’s food hygiene certificate: 6 years Name of visitors who attend an event: Destroyed after event has taken place
Holiday accommodation on the Reay Forest Estate	Reviewed yearly to determine who has stayed with us previously and could be entitled to a discounted rate
Management of the natural environment on the Abbeystead Estate, Eaton Estate or Reay Forest Estate	For those undertaking specific activities, we will use some of your personal information for the purposes of keeping and maintaining the historical records of Grosvenor Estate. Grosvenor Estate’s historical records date back hundreds of years and there is a public interest in retaining these records, as such information may be used in certain circumstances for historical research. The personal information kept for the purposes of historical records will be limited to basic identifying information. In respect of current or recent information about you, we believe that your fundamental right to privacy is more important than any public interest in our records. We have a legitimate interest in keeping this information as it will later become an important historical record but, in order to protect your privacy, the information that we collate for use in our historical records will be kept confidential for a period of 100 years after collection. During that period, access to your personal information will be restricted to certain individuals within the Grosvenor Estate and will not be made available to the public. In all other cases 6 years once specific activity has finished
Sporting activities (including fishing, stalking and shooting)	For those undertaking sporting activities, we will use some of your personal information for the purposes of keeping and maintaining the historical records of Grosvenor Estate. Grosvenor Estate’s historical records date back hundreds of years and there is a public interest in retaining these records, as such information may be used in certain circumstances for historical research. The personal information kept for the purposes of historical records will be limited to basic identifying information. In respect of current or recent information about you, we believe that your fundamental right to privacy is more important than any public interest in our records. We have a legitimate interest in keeping this information as it will later become an important historical record but, in order to protect your privacy, the information that we collate for use in our historical records will be kept confidential for a period of 100 years after collection. During that period, access to your personal information will be restricted to certain individuals within the Grosvenor Estate and will not be made available to the public. Copies of shot gun certificates and copies of insurance forms: Only current copies are kept and only as long as required for the activity that is being undertaken. Forms signed to comply with section 11(6) of the Firearms Act 1968: 5 years
Unsolicited correspondence	Please note that it may not be possible for us to examine and assess every incoming communication we may receive. Therefore, where we have received unsolicited information (for example, where we have been sent information accidentally or sent information we do not require for our purposes or have not asked for), this information may be treated in the same manner as requested information. Where we have been sent information which is entirely unsolicited (for example where it has been sent to us accidentally), we will attempt to identify that unsolicited information and delete it from our records. Where we have been sent unsolicited information alongside personal information which we have requested, and this unsolicited information cannot be separated from the information which we have a legitimate interest to process, this unsolicited information will be retained in accordance with this privacy policy.
Sales of produce (i.e. venison and logs) and services (i.e. arboriculture and landscaping)	Enquiry only: Only as long as required to answer the enquiry Financial information: 6 years Contact information: Only kept as long as required to provide deliveries and/or carry out services Marketing communications: We will only keep your information for marketing communications for as long as you agree you receive these communications
Security activities, including CCTV, use of dashboard cameras, use of body worn cameras, two-way radios and automatic number plate recognition	Automatic number plate recognition: Reviewed yearly CCTV, body worn cameras, and two-way radios: 30 days, unless required for evidential purposes Dashboard cameras: 2-5 hours, unless required for evidential purposes
Supporting the local community on the Abbeystead Estate, Eaton Estate or Reay Forest Estate	In some cases we will use some of your personal information for the purposes of keeping and maintaining the historical records of Grosvenor Estate. Grosvenor Estate’s historical records date back hundreds of years and there is a public interest in retaining these records, as such information may be used in certain circumstances for historical research. The personal information kept for the purposes of historical records will be limited to basic identifying information. In respect of current or recent information about you, we believe that your fundamental right to privacy is more important than any public interest in our records. We have a legitimate interest in keeping this information as it will later become an important historical record but, in order to protect your privacy, the information that we collate for use in our historical records will be kept confidential for a period of 100 years after collection. During that period, access to your personal information will be restricted to certain individuals within the Grosvenor Estate and will not be made available to the public. In all other cases 6 years once specific activity has finished
Visitors to the Abbeystead Estate, Eaton Estate or Reay Forest Estate	1 year
Work experience	Personal details form: Destroyed after the work experience has taken place. Name, duration of work experience and department where work experience took place: 6 years after end of work experience

How do we protect your personal information?

We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this notice.

All information you provide to us is stored securely, including in a physically secure environment, on our secure servers, and on third party secure servers in relation to our customer relationship management system.

Access to your personal information will be restricted to such employees and other individuals as are necessary for the purposes for which the information was collected.

What rights do you have in respect of your personal information?

You have the right to be informed

We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this notice to do just that, but if you have any questions or require more specific information, you can contact us (see contact details above).

You have the right to access your personal information

You have the right to ask us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:

Why we have been using your information
What categories of information we were using
Who we have shared the information with
How long we envisage holding your information

In order to maintain the security of your information, we will have to verify your identity before we provide you with a copy of the information we hold.

You have the right to correct any inaccurate or incomplete personal information

You have the right to amend any inaccurate information about you which we hold. If you believe that your personal information needs to be corrected please contact us (see contact details above).

There may be times where it is no longer necessary for us to hold personal information about you. This only relates to the following:

The information is no longer needed for the original purpose that we collected it for
You withdraw your consent for us to use the information (and we do not have another lawful reason to use it)
You object to us using your information and we have no overriding reason to keep using it
We have used your information unlawfully
We are subject to a legal requirement to delete your information

In those situations you have the right to have your personal information deleted. If you believe one of these situations applies to you, please contact us (see contact details above).

You have the right to have a copy of your personal information transferred to you or a third party in a compatible format

Also known as Data Portability, you have the right to obtain a copy of your personal information for your own purposes. This right allows you to move, copy or transfer your personal information more easily from one IT system to another, in a safe and secure way. This right shall only apply where:

we are processing your information for the purposes of entering into or performing a contract; or
you have provided consent for us to process your information.

If you would like us to transfer a copy of your personal information to you or another organisation in a structured, commonly used and machine-readable format, please contact us (see contact details above).

You have the right to object to us using your information for our own legitimate interests

Sometimes, we use your personal information to pursue our own legitimate interests, or those of third parties (please see ‘How do we use your personal information?’ above for more information about such interests).

We aim to always ensure that your rights and information are properly protected. If you believe that the way we are using your personal information is not justified due to its impact on you or your rights, you have the right to object. Unless we have a compelling reason to continue, we must stop using your personal information for these purposes.

In order to exercise your right to object to our use of your personal information for the purposes above, please contact us (see contact details above).

You have the right to restrict how we use your personal information

You have the right to ask us to stop using your personal information in any way other than simply keeping a copy of it. This right is available where:

You have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify this
You have objected to us using your information for our own legitimate interests and we are in the process of considering your objection
We have used your information in an unlawful way, but you do not want us to delete your personal information
We no longer need to use the information, but you need it for a legal claim

If you believe any of these situations apply, please contact us (see contact details above).

You are not required to pay any charge for exercising your rights.

Changes to our privacy notice

Any changes we make to this privacy notice in the future will be posted on this page. Please check back to see any updates or changes to this privacy notice.

Complaints

If you wish to make a complaint about our collection or use of your personal information, please contact us (see contact details above) in the first instance so that we may seek to resolve your complaint.

If you are not satisfied with our response you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the statutory body which oversees data protection law in the UK. This is the link to the ICO website if you wish to lodge a complaint with the ICO.

This privacy notice was updated in July 2021.