England and Wales Privacy Addendum: Plinth Data

Applies to: England and Wales data in the Service, meaning information drawn from the Charity Commission for England and Wales register, the accounts charities file with it, and grant data published to 360Giving, as shown on the /uk pages.

Effective: 22 October 2026 · Version: 1.0

This addendum supplements the Privacy Notice, which continues to apply in full. Each section below carries the code of the section of the Privacy Notice it supplements.

A4. Where it is held#

The /uk pages and the routes that serve their data run in the United Kingdom, in Vercel's London region. The England and Wales data and the filed accounts documents are stored on Google Cloud in London.

Filed accounts documents are read by automated means. Text recognition runs on Google Cloud in London. The text, as filed, is then sent to AI model providers in the United States to extract the grant lines the Service shows and to match the funders and recipients they name to the Charity Commission register.

Those providers act for us under contract. Every request passes through Vercel's AI gateway, which sends it to Baseten, which runs the model that reads the grant lines, or to TypeSafe, which runs the model that matches names to the register. Each request is sent with the gateway's zero data retention setting, so it goes only to providers that do not retain it. We also use Anthropic's Claude models to check samples of the extracted lines against the documents.

For these transfers we rely on the UK Extension to the EU–US Data Privacy Framework, under which Vercel is certified, and, for Anthropic, on the International Data Transfer Addendum to the EU Standard Contractual Clauses.

Where the Service identifies shared trusteeships, trustees are matched across charities by our own software in the UK, from the trustee lists the Charity Commission publishes. No AI model is used for this.

B1. What we hold#

In addition to what B1 of the Privacy Notice lists, the Service holds, for charities in England and Wales:

• filed accounts documents as the charity filed them with the Charity Commission, together with the text read from them. These documents commonly name trustees, and can name senior staff, donors, grant recipients and other individuals the charity chose to mention;
• grant lines read from those documents and from 360Giving data: the funder, the recipient, the amount, the stated purpose and the page each line was read from;
• register details of each charity: its name, number, registration status, income, areas of operation, causes and activities as described to the Charity Commission, and its website; and
• shared trusteeships, meaning that the same person is a trustee of two charities, derived from the trustee lists the Charity Commission publishes.

Sources: the Charity Commission for England and Wales register and the accounts filed with it, and grant data published to 360Giving under licences that do not require share-alike. Never the individuals themselves.

B2. What we do not publish#

Where a grant line names a private individual, whether as a donor, a recipient or a funder, the Service's own text does not show the name. It shows a description such as "An individual" in its place. The name is removed on our servers, before the data reaches the page. Everything on that line that would lead to the name is removed with it: the link to the filing page, the page reference and the 360Giving record.

Grants that 360Giving publishers record as made to individuals are left out. We show only their number and total amount.

Where the Service shows that two charities share a trustee, it names the charities and not the trustee. Charity Commission trustee lists are public, so the trustee may still be identifiable from the register.

Filed accounts documents. The Service lets you open the accounts document a figure was read from. We show documents as filed and do not redact them, so they can name trustees, senior staff and others, including a private individual whose name the Service's own text withholds, as they do on the Charity Commission register. Where the viewer shows the text read from a page, any line that prints a withheld name is blanked.

If we have missed one. If you come across a private individual named in the Service's own text where you would not expect one, please tell us at data@useplinth.com and we will remove it. You do not need to be the person named, and you do not need to explain why you are asking.

B3. Why we publish the rest#

Our lawful basis is legitimate interests (Article 6(1)(f) UK GDPR): the public interest in transparency and accountability in charitable funding, and the interest of charities, funders, researchers, journalists and the public in understanding who funds whom. We have carried out a legitimate interests assessment specific to England and Wales data, and you can ask us for a summary of it.

Charities in England and Wales file their accounts with the Charity Commission, which publishes them on its register. We show the same documents, beside the grant lines read from them, so that each figure can be checked against its source.

Shared trusteeships. The second purpose described at B3 of the Privacy Notice, identifying shared board connections, applies to England and Wales data on the same terms, with one difference: for England and Wales the Service shows only that two charities share a trustee, and does not name the trustee.

Special category data. The Service's own text does not publish special category data about individuals. A filed accounts document can contain it, because the charity included it; that is a further reason we withhold private individuals' names from our own text, as described at B2.

B5. If you are named#

If you are named in England and Wales data, B5 of the Privacy Notice applies to you in the same way and on the same terms. To ask us to remove something, email data@useplinth.com with the charity and the page. For any other request about your personal data, write to support@useplinth.com.

Where your name appears in a filed accounts document shown through the Service, we will stop showing that document through the Service on request. We cannot change the copy the Charity Commission publishes on its register.

Suppression persists. We rebuild the England and Wales data from time to time. Every suppression is recorded and applied again on each rebuild, so that suppressed information does not reappear.

B6. Safety#

If publication puts you at risk of harm, say so and mark the email urgent. We suppress first and assess afterwards. This holds for England and Wales data, filed accounts documents included.

C1. UK and EU#

The rights set out at C1 of the Privacy Notice apply to England and Wales data in full, under the UK GDPR and the Data Protection Act 2018. If you are named in the Service rather than a user of it, Part B of the Privacy Notice and this addendum are the parts that concern you, and B5 is the route.

Retention. We keep filed accounts documents, the text read from them and the grant lines built from them for seven years after the end of the financial year the filing covers, so that funding can be compared across years, and then delete them. Suppression records are kept for as long as the Service holds England and Wales data, so that suppressions keep applying.

If we have not resolved it. Come to us first if you can. You may also complain to the Information Commissioner's Office (ico.org.uk, 0303 123 1113).