Last updated: June 2026

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This Privacy Policy explains how the Governmental Financial Resilience Toolkit (GFR Toolkit) collects, uses, stores, protects, and shares personal data. It is intended to meet transparency requirements under the UK GDPR, the Data Protection Act 2018, and the EU General Data Protection Regulation, where applicable.

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The GFR Toolkit is a web application used to collect responses, authenticate users, generate dashboards and visual reports, support analytics, and, where enabled, provide AI-assisted analysis. By using the GFR Toolkit you acknowledge that your personal data will be handled as described in this Privacy Policy.

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1. Who we are

 

The GFR Toolkit is operated for research purposes by the Public Services Accounting and Accountability Research Group, an independent research collaboration. The research collaboration is not itself a separate legal entity. For data protection purposes, responsibility for the personal data processed through the GFR Toolkit rests with the researchers who determine the purposes and means of the processing. Where those decisions are made jointly by more than one researcher, the relevant researchers act as joint controllers.

 

Because the chair or lead contact of the research group may change over time, the current lead contact and research team contact details are maintained at: https://psaagirspm.wixsite.com/psaag

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You can also contact the GFR Toolkit privacy contact directly at: gfr.toolkit@gmail.com

 

If the toolkit is used on behalf of a local authority, public body, university, or other organisation that decides the purpose and use of the data, that organisation may be the controller for that use. In that case, the GFR Toolkit research team may act as a processor, joint controller, or independent research controller depending on the agreed arrangement.

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2. What this policy applies to

 

This policy applies to personal data processed through:

• the GFR Toolkit web application;

• Google Forms used to collect responses for the toolkit;

• authentication through Auth0 using one-time password login by email;

• dashboards, analytics reports, charts, RAG scoring, heatmaps, and visual reports generated from submitted responses;

• AI-assisted features using Google Cloud / Gemini Enterprise services, where enabled;

• research analysis using data submitted through or connected to the toolkit.

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3. Personal data we collect

 

We aim to collect only the personal data needed to operate the GFR Toolkit and carry out the purposes described in this policy. Depending on how you use the toolkit, we may collect:

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Account and authentication data

• email address;

• authentication profile information;

• login and access information processed through Auth0;

• session and security information needed to protect access to the toolkit.

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Organisation and grouping data

• local authority, municipality, council, organisation, department, team, or similar grouping;

• role, service area, or department, if included in the form or dashboard configuration.

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Form and survey response data

• responses submitted through Google Forms or other toolkit forms;

• scores and survey responses;

• answers used to generate dashboards, comparisons, RAG scores, reports, and visual summaries.

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Form responses are not designed to include sensitive or confidential information.

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Dashboard and analytics data

• dashboard views or interactions where needed for security, operation, or user access;

• generated analytics, visual reports, charts, dashboards, RAG scores, departmental averages, local authority comparisons, and aggregated performance indicators.

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AI-related data, where AI features are used

Where AI-assisted features are enabled, we may process:

• prompts or questions submitted by users;

• relevant dashboard or form-response context needed to generate an answer;

• uploaded datasets, if upload functionality is enabled;

• AI-generated outputs, such as summaries, explanations, charts, visual reports, or dashboard commentary.

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Technical and security data

We may collect technical information needed to operate and secure the application, such as:

• browser and device information;

• IP address or approximate location derived from access logs;

• session identifiers;

• error logs;

• security logs;

• audit records;

• date and time of access.

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4. Special category or sensitive data

 

The GFR Toolkit is not designed to intentionally collect special category data. Special category data may include information about health, ethnicity, racial origin, political opinions, religious beliefs, trade union membership, sexual orientation, sex life, genetic data, or biometric data used for identification. Users should not submit special category data, confidential information, or information about identifiable individuals.

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5. How we collect personal data

 

We collect personal data in the following ways:

• directly from you when you complete a Google Form or submit information through the toolkit;

• through Auth0 when you authenticate using a one-time password sent by email;

• automatically through technical, access, and security logs when you use the application;

• through dashboards and analytics workflows that process submitted responses;

• through AI-assisted features where you choose to submit prompts, uploaded data, or other relevant context.​

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6. Why we use your personal data

 

We use personal data for the following purposes:

 

To authenticate users and manage secure access

We use your email address and authentication information to confirm your identity, protect access to the toolkit, and ensure users can only access the data or dashboards they are authorised to see.

 

To collect and analyse responses

We use Google Forms and related storage tools to collect responses and prepare them for analysis.

 

To generate dashboards, reports, and visual analysis

We use submitted responses to generate dashboards, charts, reports, heatmaps, RAG scoring, comparative analysis, departmental summaries, local authority comparisons, and aggregated averages.

Users may be able to view their own responses alongside aggregated departmental, organisational, or overall results, depending on the dashboard configuration.

 

To support organisational learning and improvement

We may use aggregated and analysed results to identify patterns, compare results across departments or local authorities, support internal performance evaluation, and inform government improvement initiatives.

 

To provide AI-assisted features

Where enabled, we use AI-assisted processing to help generate summaries, explanations, dashboards, reports, charts, visualisations, and analytical commentary.

 

To conduct research

We may use data submitted through or connected to the GFR Toolkit for research purposes. This may include academic, professional, policy, public administration, public sector, or organisational research.

Research use may include:

• analysing response patterns;

• comparing aggregated results across local authorities, departments, or organisations;

• identifying trends;

• preparing academic or professional research outputs;

• producing publications, presentations, reports, case studies, or policy analysis.

Where possible, research will be conducted using anonymised or aggregated data so that individuals are not identifiable.

 

To maintain security and prevent misuse

We use technical and security data to protect the toolkit, monitor access, prevent unauthorised use, investigate issues, and maintain reliable operation.

 

To comply with legal and regulatory obligations

We may process and retain certain information where necessary to comply with legal obligations, respond to lawful requests, resolve disputes, or enforce agreements.

 

7. Lawful basis for processing

 

We only process personal data where we have a lawful basis under applicable data protection law.

Depending on the context, our lawful bases may include consent, which you may withdraw your consent at any time by contacting gfr.toolkit@gmail.com. Withdrawal of consent does not affect processing carried out before consent was withdrawn. Specifically, where research outputs have already been anonymised, aggregated, or published in a way that no longer identifies individuals, withdrawal may not affect those outputs.

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8. Consent for research use

 

If your data is used for research, we will make this clear before or at the point of collection.

Where research use is based on consent, you will be asked to agree to that use. Research consent should be separate from any consent required to use the toolkit, unless participation in the toolkit and the research are part of the same defined project. Research will use anonymised or aggregated data. We will not publish your email address, individual-level responses, or information that directly identifies you without your explicit permission. If research is carried out through a university, funder, public body, or formal research project, additional participant information or ethics documentation may also apply.

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9. AI-assisted features and Google Gemini Enterprise

 

Some features of the GFR Toolkit may use Google Cloud / Gemini Enterprise services to assist with automated data processing, analytics, report generation, charts, visual summaries, dashboard commentary, and other outputs requested by users. When AI-assisted features are used, prompts, uploaded content, submitted responses, generated outputs, and relevant context may be processed by Google Cloud services to provide the requested functionality.

AI processing is automated. We do not routinely manually review user prompts, uploaded datasets, submitted responses, or generated outputs. Access is limited to authorised systems and authorised personnel where necessary for security, support, maintenance, legal compliance, or exceptional circumstances.

 

Under the applicable Google Cloud / Gemini Enterprise terms and our configuration, customer data processed through these services is not used by Google to train or fine-tune public AI models unless this is expressly permitted or instructed by the customer. Users should only submit personal, sensitive, confidential, or organisational data where it is necessary for the requested analysis and where they are authorised to do so - and this is not required by the GFR Toolkit.

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10. Automated decision-making and profiling

 

The GFR Toolkit may generate automated analysis, dashboards, RAG scores, comparisons, summaries, or AI-assisted outputs. These outputs are intended to support analysis, reporting, research, and decision-making by users. Unless we tell you otherwise, the toolkit does not make solely automated decisions about individuals that produce legal or similarly significant effects. We do not use your personal data for direct marketing or behavioural advertising.

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11. How we store your data

 

Personal data may be stored or processed using the following systems:

• Google Forms, used to collect responses;

• Google Sheets or Excel spreadsheets, used to store and prepare collected responses;

• Google Cloud App Engine, used to host the web application;

• Auth0, used for authentication and one-time password access;

• Google Cloud / Gemini Enterprise services, where AI-assisted features are enabled;

• business intelligence or dashboard tools used to generate reports and visualisations;

• secure administrative or support systems used to operate the toolkit.

The application is hosted on Google Cloud via Cloud Run in London, United Kingdom, based on the current hosting configuration.

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12. Who we share personal data with

 

We do not sell personal data. We may share or process personal data with trusted service providers only where necessary to operate, secure, analyse, host, support, or improve the GFR Toolkit.

These providers may include:

• Google Cloud, for hosting, infrastructure, storage, and AI-assisted processing;

• Google Forms and Google Sheets, for form collection and response storage;

• Auth0, for authentication;

• business intelligence, reporting, or dashboard tools;

• technical support, monitoring, security, or maintenance providers, where applicable.

 

Where service providers process personal data on our behalf, we require appropriate contractual, confidentiality, and security safeguards. We may also disclose personal data where required by law, court order, regulator request, enforceable government request, or other legal obligation.

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13. International transfers

 

We aim to store and process personal data in the United Kingdom or European Economic Area where possible, and the GFR Toolkit application is currently hosted on Google Cloud App Engine in London, United Kingdom.

However, some service providers may process, support, access, or maintain services from other countries, including where necessary for security, support, maintenance, backup, service delivery, or legal compliance.

Where personal data is transferred outside the UK or EEA, we rely on appropriate lawful safeguards, such as adequacy regulations, standard contractual clauses, the UK International Data Transfer Agreement or Addendum, or other valid transfer mechanisms under applicable data protection law. We do not intentionally transfer personal data outside the UK or EEA unless an appropriate legal basis or safeguard is in place.

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14. Security

 

We use administrative, technical, and organisational safeguards designed to protect personal data from unauthorised access, disclosure, alteration, loss, or misuse.

These safeguards may include:

• HTTPS encryption for data in transit;

• access controls;

• protected routes using Auth0 authentication;

• one-time password login by email;

• role-based or permission-based access where applicable;

• restriction of dashboard access so users see only data they are authorised to view;

• secure hosting infrastructure;

• logging and monitoring for security and operational purposes;

• limited administrative access;

• separation of environments where applicable;

• secure storage and backup controls where applicable.

No internet-based service can be guaranteed to be completely secure. Users should also take care not to submit unnecessary sensitive or confidential information.

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15. Data retention

 

We keep personal data only for as long as necessary for the purposes described in this policy, including operating the toolkit, generating dashboards, supporting research, maintaining security, resolving disputes, complying with legal obligations, and enforcing agreements. Unless a different retention period is agreed for a specific project:

• authentication and account data will be kept while your account remains active or while access is required;

• form responses will be kept for the duration of the relevant project, research activity, reporting period, or service agreement;

• dashboard and analytics data will be kept for as long as needed to provide the toolkit and related reports;

• security and access logs will be kept for a limited period needed for security, audit, troubleshooting, or legal purposes;

• anonymised or aggregated research outputs may be retained indefinitely, provided individuals are no longer identifiable.

Where possible, personal data will be deleted, anonymised, or aggregated when it is no longer required.

Specific retention periods may be confirmed in a project agreement, participant information sheet, research protocol, or organisational data retention schedule.

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16. Cookies and similar technologies

 

The GFR Toolkit does not directly use cookies for advertising or marketing.

Auth0 and related authentication services may use cookies or similar technologies to provide secure login, maintain sessions, and protect the application from misuse.

Technical cookies or session technologies may be necessary for the toolkit to function properly.

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17. Your data protection rights

 

Depending on your location and the circumstances of processing, you may have the following rights under UK GDPR and EU GDPR:

• the right of access: to request a copy of the personal data held about you;

• the right to rectification: to ask for inaccurate or incomplete data to be corrected;

• the right to erasure: to ask for your personal data to be deleted in certain circumstances;

• the right to restrict processing: to ask us to limit how your data is used in certain circumstances;

• the right to object: to object to processing in certain circumstances;

• the right to data portability: to receive certain personal data in a structured, commonly used, machine-readable format;

• rights related to automated decision-making and profiling;

• the right to withdraw consent, where processing is based on consent.

To exercise your rights, contact: gfr.toolkit@gmail.com

 

If your organisation is the controller of your data, we may need to refer your request to that organisation or work with them to respond. Some rights may be limited where data must be retained for legal, security, audit, research integrity, or legitimate operational reasons. If we cannot fulfil a request, we will explain why where required by law.

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18. Research outputs and anonymised data

 

Research outputs may include aggregated statistics, charts, dashboards, academic publications, professional reports, presentations, policy analysis, or case studies. We will not publish individual-level responses, email addresses, or information that directly identifies you without your explicit permission. Where research outputs are anonymised so that individuals are no longer identifiable, those outputs may be retained, shared, or published without further notice, because anonymised information is no longer personal data. Where data is pseudonymised rather than anonymised, it remains personal data and will continue to be protected under this policy.

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19. Children’s data

 

The GFR Toolkit is not intended for use by children. We do not knowingly collect personal data from children unless this has been specifically agreed as part of an authorised project with appropriate safeguards.

 

20. Changes to this policy

 

We may update this Privacy Policy from time to time.

If we make significant changes, we will notify users by posting the updated policy in the application and, where appropriate, by email or through the relevant organisation.

The “Last updated” date at the top of this policy shows when it was last revised.

 

21. How to contact us

 

For questions about this Privacy Policy, privacy practices, or your data protection rights, contact:

Email: gfr.toolkit@gmail.com
 

22. How to complain

 

If you are not satisfied with how we handle your personal data or respond to a privacy request, please contact us first so we can try to resolve the issue.

You also have the right to complain to the Information Commissioner’s Office in the United Kingdom:

Information Commissioner’s Office
Website: https://ico.org.uk/make-a-complaint/
Phone: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If you are located in the European Economic Area, you may also complain to your local data protection supervisory authority.