Last updated: October 2026
1. Introduction
Data protection and privacy are of the highest importance to Swoboda Research Centre (“Swoboda”, “we”, “us”). Swoboda Personnel shall at all times maintain in strictest confidence and not disclose outside Swoboda any Personal Data and/or Confidential Information that comes into their possession in the course of their employment or other activities with Swoboda. This basic principle shall be understood and applied as broadly as possible and shall have no exceptions whatsoever except as specifically stated in this policy.
This policy also explains what Personal Data we collect, why we collect it, how long we keep it, and what your rights are, including when you visit our website or we contact you.
2. Definitions
2.1 “Swoboda” means Swoboda Research Centre, a company limited by guarantee registered in the Republic of Ireland (company number 593017), and any other Swoboda owned or affiliated entity.
2.2 “Data Protection Laws” means the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the Data Protection Acts 1988 to 2018, the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (S.I. No. 336 of 2011), and any other applicable data protection law in Ireland.
2.3 “Personal Data” means the Personal Data of any individual whether in paper, electronic or any other form as defined in the Data Protection Laws.
2.4 “Swoboda Personnel” means all Swoboda directors, officers and employees and all contract researchers, writers and other outside contractors who collect, control or process Personal Data and/or Confidential Information in connection with their services to Swoboda.
2.5 “Research Subject” means an individual whose Personal Data is collected in the course of an interview, survey or other research conducted by Swoboda Personnel.
2.6 “Non-Public” means information that has not been published or otherwise made available to the public by the owner of that information or by operation of law, and it includes information that has been made public or otherwise disclosed in violation of a duty of confidentiality to the owner of such information.
2.7 “Confidential Information” means any Non-Public information of any kind related to or belonging to Swoboda and for purposes of this policy and notwithstanding 2.6, Personal Data shall in all cases be deemed to be Non-Public.
3. General Principles
Swoboda is a Data Controller under the Data Protection Laws and all Personal Data will be maintained in accordance with the obligations of that law and regulations adopted thereunder. Data protection safeguards the privacy rights of individuals in relation to a Data Controller’s possession of their Personal Data, whether held in paper or electronic format. The Data Protection Laws prescribe strict rules about the way in which Personal Data are collected, accessed and used, and give individuals the rights set out in section 10. The purpose of this policy is to help ensure that we comply with the Data Protection Laws.
4. Data Protection Policy
4.1 This policy is a statement of Swoboda’s commitment to protect the rights and privacy of individuals as required by the Data Protection Laws.
4.2 All Swoboda Personnel who collect, control, use or process Personal Data are individually responsible for compliance with the Data Protection Laws. Swoboda considers that, given the nature of its activities, a Data Protection Officer is not required; the Directors co-ordinate the provision of support, assistance, advice and training within Swoboda to ensure that Swoboda complies with the Data Protection Laws.
4.3 Swoboda conducts an annual internal data audit to ensure it maintains a comprehensive picture of what data Swoboda has collected, how it is stored, how it is managed and, where appropriate, erased.
4.4 Personal Data shall be used by Swoboda Personnel exclusively for Swoboda’s legitimate research, administrative and other business purposes and shall not be disclosed outside Swoboda except for such purposes and then only to such contractors, advisors, data processors and other persons having the same legal obligation of data protection and confidentiality that apply to Swoboda Personnel under the Data Protection Laws and this policy, except only as otherwise permitted by this policy.
4.5 The Personal Data of Research Subjects shall, to the extent practical and consistent with sound research standards, be gathered by Swoboda Personnel on an anonymous basis such that it cannot be identified to any particular individual. The only exceptions will be:
4.5.1 transcripts, recordings, notes and other records of interviews or conversations with Research Subjects, or
4.5.2 materials submitted to Swoboda by Research Subjects containing personal information that documents the Research Subject’s identity and capacity, or
4.5.3 any other materials which, in the judgment of a Swoboda Director, need to retain information regarding a Research Subject’s identity and capacity to permit subsequent verification and validation of research results.
4.6 Swoboda gathers Personal Data of Research Subjects solely for purposes of providing research results, aggregate information and anonymised quotes and examples for analysis, consultation, advice, training and reports to and for Swoboda members and clients. The results of such research and analysis, but NOT the underlying Personal Data, will be provided to members and clients, and in some cases to the general public, in the form of reports and research papers. Any example of Personal Data included in such research and results shall always be presented in a completely anonymised manner so that the individual to whom it relates cannot be identified. The only exceptions are interview quotations, comments, etc. that include other information (e.g. name, job title) which the Research Subject expressly consents to being published by Swoboda.
4.7 An assessment of qualifying Personal Data will be undertaken at the commencement of each project. Swoboda will require the providers of such Personal Data to confirm that all necessary consents are in place to permit sharing such Personal Data with Swoboda and Swoboda’s use thereof in compliance with this policy.
4.8 Swoboda Personnel shall perform our responsibilities under the Data Protection Laws in accordance with the following principles:
4.8.1 We shall obtain and use Personal Data fairly, lawfully and transparently, in accordance with our statutory and other legal obligations as well as our contracts and other agreements with clients and other data providers.
4.8.2 We shall use Personal Data only for the purposes set out in this policy.
4.8.3 We shall use Personal Data only in circumstances that are necessary for our services, and we shall not disclose Personal Data to anyone except (a) the client or other data provider from or on behalf of whom we received that particular Personal Data or (b) as otherwise permitted by this policy.
4.8.4 We shall take appropriate security measures to protect against unauthorised access to, or alteration, disclosure or destruction of, Personal Data and against its accidental loss or destruction.
4.8.5 Swoboda shall only hold Personal Data to the extent that it is adequate, relevant and not excessive, and shall keep it accurate and up to date.
4.8.6 In the event we receive a request from an individual to provide, erase or correct their Personal Data, we shall do so promptly, and within one month, in accordance with their rights under the Data Protection Laws.
4.8.7 In the event of a personal data breach that is likely to result in a risk to individuals, we shall notify the Data Protection Commission within 72 hours and inform the individuals affected where required by law.
5. Personal Data We Collect and Why
We collect and use Personal Data for the following purposes, relying on the lawful bases set out in Article 6 of the GDPR:
- Members, clients and partners: names, job titles and work contact details, to provide membership, research, advice, training and partnership services (performance of a contract).
- Research Subjects: interview and survey responses, as described in section 4 (consent, or our legitimate interests in carrying out research for our members).
- Event bookings and purchases: name, organisation, contact and billing details (performance of a contract). Card payments are processed by our payment provider and we do not see or store full card details.
- Newsletters and website notifications: contact details or a browser token, only where you have asked to receive them (consent, which you can withdraw at any time).
- Applications: information you provide when applying for membership, partnership or other opportunities, so that we can assess your application (steps taken at your request before entering into a contract).
- Contacting organisations about our work: as described in section 7 (legitimate interests).
- Website Visitors: cookie-free usage statistics, as described in section 6 (legitimate interests).
Where we rely on legitimate interests, we have considered that our interests are not overridden by your rights and freedoms, and you may object at any time. We do not use Personal Data for automated decision-making or profiling that has legal or similarly significant effects.
6. Our Website, Cookies and Analytics
6.1 We use analytics software hosted on our own website server to understand how our website is used. It is configured not to place cookies or similar technologies on your device, and IP addresses are shortened before they are stored so that individual visitors cannot be identified. Detailed records are deleted after 180 days. This data is not shared with third parties or used for advertising.
6.2 Some links in our emails include a short code unique to the receiving organisation. When the link is followed, we can see that someone from that organisation visited the page, which parts of the page were viewed, and whether the application link was used. The code identifies an organisation, not an individual.
6.3 We use cookies that are strictly necessary for the website to function, for example to complete a booking or payment or to log in. These do not require consent. We do not use advertising cookies. Where any other cookies are used, we will only place them with your consent.
7. Contacting Organisations About Our Work
7.1 We may contact people at organisations whose work is relevant to credit unions and the community finance sector, for example to invite them to become a member or partner. We use business contact details only, obtained from organisation websites, professional networks, events, and email verification services.
7.2 We do not use tracking pixels and we do not record whether you open our emails.
7.3 If you do not wish to hear from us, reply to our email or contact us using the details in section 12. We will stop contacting you and keep only the minimum details needed to make sure we do not contact you again.
8. Sharing Personal Data
8.1 We never sell Personal Data. We share it only with service providers who act on our instructions under written agreements, including providers of email and office software, website hosting, payment processing, newsletter delivery and email verification, and with professional advisers or authorities where required by law.
8.2 Some service providers may process data outside the European Economic Area. Where they do, we ensure appropriate safeguards are in place, such as an adequacy decision of the European Commission (including the EU-US Data Privacy Framework) or the European Commission’s Standard Contractual Clauses.
9. Data Retention
Swoboda will retain Personal Data only for as long as is necessary for the purpose for which it was collected, including to meet legal, accounting and reporting requirements, after which it will be securely and permanently erased or anonymised. Anonymised or aggregate research data may be kept indefinitely. This retention policy does not apply to Personal Data that has been published by Swoboda in accordance with this policy and the Data Protection Laws.
10. Your Rights
Under the Data Protection Laws you have the right to:
- access the Personal Data we hold about you
- have inaccurate Personal Data corrected
- have your Personal Data erased
- restrict how we use your Personal Data
- object to our use of your Personal Data, including for direct marketing
- data portability, where processing is based on consent or a contract
- withdraw your consent at any time, where we rely on consent
To exercise any of these rights, please contact us using the details in section 12. There is no charge, and we will respond within one month. You also have the right to lodge a complaint with the Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28 (www.dataprotection.ie).
11. Confidentiality Policy
This policy is a statement of Swoboda’s commitment to maintain in strictest confidence its own and all client and member Confidential Information and to not disclose it except as specifically permitted by this policy.
11.1 Swoboda Personnel shall at all times maintain utmost secrecy in regard to the affairs of Swoboda and shall keep confidential any information, documents, data files etc. relating to Swoboda, its members, clients and Research Subjects that may come to their knowledge in the course of their work for Swoboda.
11.2 Swoboda Personnel shall not disclose Confidential Information except to other Swoboda Personnel who have a need to know and who have permission from Swoboda to receive it.
11.3 Swoboda Personnel shall take special care in public places (e.g. restaurants, aeroplanes, lifts) to ensure that even casual conversation or inadvertent displays of written material do not lead to the disclosure of any Confidential Information.
11.4 After termination of employment or other engagement with Swoboda, Swoboda Personnel shall immediately return all Confidential Information to Swoboda.
11.5 Before commencing any work for Swoboda that may involve access to Confidential Information, Swoboda Personnel shall sign an employment or other non-disclosure agreement that obliges them to comply with the requirements of this policy as a condition of their employment or other relationship with Swoboda.
12. Inquiries
Inquiries about this policy, or requests relating to your Personal Data, should be made to:
Nick Money, Director of Development
Swoboda Research Centre
24 Court Street, Enniscorthy, Co. Wexford, Ireland, Y21 H6C8
enquiries@swobodacentre.org
13. Changes to This Policy
We review this policy regularly and will post any changes on this page, with the date it was last updated.
Swoboda Research Centre, Republic of Ireland company limited by guarantee, registered in Dublin, number 593017.
