Company number: 4354366 Charity number: 1147471
## Privacy International
Report and financial statements For the year ended 31 January 2025
**Privacy International**
## **Contents**
## **For the year ended 31 January 2025**
Reference and administrative information .............................................................................................................................................. 1 Trustees’ annual report ................................................................................................................................................................................ 2 Independent auditor’s report ................................................................................................................................................................... 14 Statement of financial activities (incorporating an income and expenditure account) ................................................................ 18 Balance sheet ............................................................................................................................................................................................... 19 Statement of cash flows .............................................................................................................................................................................. 20 Notes to the financial statements ............................................................................................................................................................. 21
**Privacy International**
## **Reference and administrative information**
## **For the year ended 31 January 2025**
**Company number** 4354366 **Country of incorporation** United Kingdom **Charity number** 1147471 **Country of registration** England & Wales
**Registered office and operational address** 62 Britton Street, London, EC1M 5UY
|**Trustees**|Trustees, who are also directors under company law, who served during the year and up to|Trustees, who are also directors under company law, who served during the year and up to|
|---|---|---|
||the date of this report were as follows:||
||Holly Marie Ruthrauff|Resigned 31 December 2024|
||Stephen Josef Tibbett|Resigned 31 October 2024|
||Antonio Michaelides|Resigned 28 February 2025|
||Ahana Datta||
||Joshua Castellino||
||Amanda Borton||
||Mahdis Keshavarz||
||Martin Georgi||
||Sara Fratti|Appointed 01 May 2025|
||Vera Franz|Appointed 01 May 2025|
||Martin Scheinin|Appointed 01 May 2025|
|**Bankers**|Barclays Bank||
||1 Churchill Place||
||London E14 5HP||
|**Solicitors**|Covington & Burling||
||22 Bishopsgate||
||London EC2N 4BQ||
|**Auditor**|Sayer Vincent LLP||
||Chartered Accountants and Statutory Auditor||
||110 Golden Lane||
||LONDON||
||EC1Y 0TG||
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**Privacy International**
## **Trustees’ annual report**
## **For the year ended 31 January 2025**
The trustees present their report and the audited financial statements for the year ended 31 January 2025.
Reference and administrative information set out on page 1 forms part of this report. The financial statements comply with current statutory requirements, the memorandum and articles of association, the requirements of a directors’ report as required under company law, and the Statement of Recommended Practice - Accounting and Reporting by Charities: SORP applicable to charities preparing their accounts in accordance with FRS 102.
## Objectives and activities
## Purposes and aims
Privacy International's objects are to promote privacy as a human right (as set out in the Universal Declaration of Human Rights) throughout the world, specifically:
- a) To raise awareness of, to conduct research about, and to provide educational materials regarding threats to personal privacy;
- b) To monitor and report on surveillance methods and tactics employed against individuals and groups;
- c) To work at national and international levels towards the provision of strong and effective privacy protections;
- d) To monitor the nature, effectiveness and extent of measures to protect privacy, and to seek ways through
- information technology to protect personal information.
## **Mission**
We campaign for legal and technological solutions to protect people and their data from exploitation. We expose harm and abuses, mobilise allies globally, campaign with the public for solutions, and pressure companies and governments to change.
## **Vision**
Freedom and privacy will be the foundations of tomorrow’s societies. People are enabled by technology to explore their identities, speak their minds, and live with dignity. They will be free from exploitation and in control of their lives.
## **Governance of Privacy International’s activities**
Privacy International’s trustees continuously review the aims, objectives and activities of the charity.
Privacy International (PI) sets multi-year strategies that the Trustees expect the organisation to deliver upon. Through annual planning of projects that contribute towards multi-year outcomes, the Trustees monitor PI’s delivery of its strategic priorities.
PI’s strategy for 2023-2026 and the strategic plan were approved by the Board of Trustees in 2022.
Every December PI establishes an annual plan that prescribes how we will organise our work to achieve change. By March every year we establish indicators for monitoring whether we are achieving results in accordance with our Monitoring & Evaluation framework. These indicators are reviewed at every Trustee meeting, alongside the organisation’s risk matrix.
In setting the annual workplan, the Board of Trustees have regard to both the Charity Commission's guidance on public benefit, and the promotion of human rights for the public benefit. The Trustees confirm that they have complied with
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**Privacy International**
## **Trustees’ annual report**
## **For the year ended 31 January 2025**
section 17 of the Charities Act 2011 and are satisfied that the aims and objects of the charity, and the activities reported on to achieve those aims, meet these principles.
## Beneficiaries of our services
Changes in practices and policies by governments and companies as a result of our work have benefited people globally, including as national publics and consumers. Direct beneficiaries of our work are i) the general public across the world through our advocacy, public engagement, and educational work, and ii) public interest civil society organisations across the world through our capacity-building and support.
## Achievements and performance
The charity's charitable activities focus on achieving change by strategically targeting our tech, legal and policy advocacy at governments and companies who are vying for power to determine the future to their advantage and to the detriment of people’s privacy. We track results on an annual basis; knowing that impact often takes longer.
## Impacts in 2024
The impacts we contributed to that arose in 2024 can be grouped around i) enhancing protections for people, ii) raising the bar against exploitation, and iii) establishing stronger standards.
The work contributing to these effects have built up over years (and we outline such work conducted in 2024 in the section on ‘tactics’).
## **i. Enhancing protections for people**
We want people to have better access to their rights, through increased protections.
## **Impact case study: improved protections for migrants subjected to GPS tagging**
The UK Government had been punitively tagging migrants with GPS ankle bracelets. Members of the migrant community wanted us to prioritise this issue. We tested the kit. We filed evidence in court cases and regulatory complaints.
In March 2024, two courts handed down rulings on the UK’s GPS tagging of migrants, dealing blows to the legality of the policy. In March 2024 UK data protection regulator also issued a decision, following from our complaint in 2022.
Now, the UK Government is forced to review and change these humiliating and invasive practices.
As other governments deploy similar ‘solutions’, we will share our analyses and advocacy experiences with others.
## **ii. Raising the bar against exploitation**
We want governments and companies to struggle to deploy disproportionate surveillance and data exploitative practices.
## **Impact case study: curtailed industry consolidation**
In 2024, Amazon and iRobot terminated their merger. That came after the European Commission’s objected to the merger and began an investigation. PI was granted ‘third person interest’ status in the EU’s review of the merger, following our submissions and our research.
This result shows Big Tech’s power can be constrained.
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**Privacy International**
## **Trustees’ annual report**
## **For the year ended 31 January 2025**
## **Legal results: informed jurisprudence**
_Russia’s law for accessing encrypted communications violates human rights, according to the European Court of Human Rights._ In the February 2024 judgement in the case of Podchasov v. Russia, the Court ruled that forcing the retention of data on internet users and requiring decrypted communications cannot be regarded as necessary in a democratic society. PI’s intervention in the case provided a technical and legal analysis of encryption and its key role in the protection of human rights, and the court cited our submission.
_Colombia is held accountable for violating the right to defend human rights including unlawful surveillance, by the InterAmerican Court of Human Rights._ The Court’s historic judgment is the first acknowledgment within the inter-American context of a state’s international responsibility for violating the right of people to defend human rights. The Court decision reflected the positions presented in our intervention, alongside other organisations, represented by the International Human Rights Law Clinic at the University of California, Berkeley.
_Mass secret surveillance in Poland is condemned by the European Court of Human Rights._ In the Pietrzak and others v Poland case, to which we intervened four years prior with Article 19 and EFF, the judgment found that Poland’s mass secret surveillance powers indeed violated the right to privacy and was not “necessary in a democratic society”.
These judgments about specific laws and cases articulate the need for reform of laws and practices. They also set precedents for other countries operating in similar fashions.
## **iii. Establishing stronger standards**
PI seeks to set positive standards that protect privacy. By informing standards we aim to improve practice globally.
## **Impact case study: new protection requirements for people’s devices and services**
European Union laws will require companies who manufacture devices and run services to provide security updates, handle vulnerabilities, and be transparent with consumers. This will increase security for hundreds of millions of people; while providing _de facto_ global effects.
In March 2024 the European Parliament approved the Cyber Resilience Act. PI engaged extensively in this policy process. The final text obliges manufacturers to ensure "effective handling of vulnerabilities” for “no less than five years”.
In January 2024 the European Parliament adopted the Directive on empowering consumers for the green transition. As a result of our advocacy the Directive reflects our demands, including that consumers will have information about the minimum period during which devices should receive security updates, accessible through a harmonised label.
## Tactics in 2024
Our tactics and methods preparing the ground for change. While some results can be seen already, we hope more will come soon.
This reporting is grouped around 1) identifying threats, 2) exposing harms and abuses, 3) advocating for change, and 4) mobilising and amplifying others.
## **1. Identifying threats**
At PI we are always looking across the world and to the future to identify the next generation of challenges.
By undertaking horizon scanning and engaging with media outlets we can identify new threats and inform public discourses around arising challenges.
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## **Trustees’ annual report**
## **For the year ended 31 January 2025**
## **Militarisation of Tech**
As a result of our horizon scanning exercises, we were able to further develop, gain funding, and launch a new project on Militarisation of Tech. In 2024 we established a multi-year fund for the sector to explore and prepare for the increased ‘militarisation of tech’. We are now building a programme of work with $1.5m USD of funding for PI and a cluster of partners. The strategic objective is: _War and conflict must not become the dominant determinant of our societies’ technologies._
In 2022 with the invasion of Ukraine and then in 2023 with the war in Gaza, we noticed a remarkable shift in the development and use of technology. Industry began shifting in many ways, including the rise of the ‘defence tech’ industry, the shift of the ‘defence industry’ towards advanced forms of tech that included data collection and surveillance, and by 2024 Big Tech began announcing formal moves to seek military contracts, including using AI.
Through developing knowledge bases around militarisation of tech and building a systemic understanding, PI will develop an initial body of evidence and compelling narratives to engage with media, civil society and other stakeholders, which will serve as a basis for future advocacy.
We are resourcing and working with arms control organisations, domain experts and researchers, investigators and journalists; as well as PI partner organisations who identified this issue as one of their priorities.
## **Media coverage**
PI’s positions and demands have been extensively covered by various national and international media outlets. We registered 272 media materials in 28 languages covering various aspects of our work.
Among others our work has been covered by: Al Jazeera, BBC, Daily Mail, Euronews, Financial Times, The Guardian, The Independent, Nature, Netzpolitik, TechCrunch, Washington Post, WIRED, The Telegraph, The Times, Tom’s Guide.
Among the most frequently covered topics were: Facial Recognition Technology, AI Tools and models, GPS tagging migrants, Automated Decision Making, Encryption, Surveillance Programs.
## **Orienting other fields**
By engaging with other actors, we can bring our perspectives and focus to their attention.
PI’s work identifying the impact of abusive use of technology on various affected populations has been recognised by international organisations. PI has been invited to take part in various consultations and deliver expert sessions, including:
- Delivering an oral intervention at the Plenary Session of the UN’s Committee on the Convention of the Rights of Persons with Disabilities during its 31st Session, in August 2024.
- Conducting a workshop with the International Labour Organization (ILO), to raise awareness and improve understanding amongst key stakeholders and policy experts in the UN framework and adjacent organisations regarding the impact of digital technologies on minority groups in the context of social protection.
- Together with the ILO, UN Office of the High Commissioner for Human Rights (OHCHR), and UNICEF, coorganising and co-delivering a workshop during which we were able to articulate our concerns, including some case studies and the legal and data protection framework, concerning digitisation of social protection and rights of persons with disabilities. Over 170 people registered for this event. The audience was largely UN officials, policymakers and some civil society representatives.
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## **Trustees’ annual report**
## **For the year ended 31 January 2025**
## **2. Exposing Harms and Abuses**
Through research, investigations and policy engagement we bring evidence to stakeholders, including communities, civil society, and key institutions. Instances over the last year include:
- We presented our work exposing the UK Government’s automated system for processing migrants data to the Immigration Lawyer Practitioner’s Association working group on digitalisation.
- We raised the risks of surveillance of students and education staff to the attention of the UN Special Rapporteur on the right to education, who included these points in her 2024 reports on the right to academic freedom and on AI.
- With our partner in Colombia, Karisma, we raised the automatic exclusion of people receiving social assistance to the attention of the UN Special Rapporteur on extreme poverty and human rights, in advance of his country visit, an issue that he then highlighted.
- At their invitation, we raised concerns to UN processes around the rights of persons with disabilities, resulting in a report critical of the UK Government, and an invitation for future collaboration with the UN Special Rapporteur on the rights of persons with disabilities.
We also continued to explore and expose effects of technological systems on migrants, indigenous communities and other vulnerable groups. For instance, in our report on privacy of indigenous communities, we present our research findings and the analyses of interviews with organisations that work directly with indigenous people, and we outline the main interrelationships between privacy, autonomy, and other Indigenous rights.
When we expose harms to stakeholders, we lay the groundwork for further action. We hope to work with them to create results and impact in years to come.
## **3. Advocating for change**
In 2024 we registered 21 instances of global and regional structures, or their members, adopting PI’s positions in their communication, initiatives, reports or decisions. These are a result of developing positions and standards that protect privacy, engaging with key policy bodies, and participating in consultation processes. Instances of these activities and results include:
## **Enhancing safeguards.**
- The Council of Europe data protection committee adopted guidelines on voter registration and authentication. The Guidelines include positions that PI recommended to the Committee, following years of work on election privacy. It will serve as a reference point for organisation and management of the election process in countries across the world.
- On invitation from OSCE’s Office for Democratic Institutions and Human Rights, we attended Declaration of Principles 2024 meeting in Gdansk. PI was the only non-election observer organisation invited to the event. We also followed-up on the DoP data and election policy paper, which is due to be adopted in 2025.
## **Improvements to draft laws.**
- Improvements to surveillance draft legislation in South Africa. Following a joint public statement, with other organisations, and comments to Parliament, on the draft General Intelligence Laws Amendment Bill 2023 (GILAB), the National Assembly adopted the third version of GILAB incorporating many of our suggestions. This included the removal of the provision allowing security vetting of non-profit organisations, churches, and
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**Privacy International**
## **Trustees’ annual report**
## **For the year ended 31 January 2025**
their personnel; and improved its regulation of mass interception with stricter controls on data management and protections. The Bill, now before the National Council of Provinces for consideration, still has shortcomings that need to be addressed.
- Nigerian draft law expands to consider the role of private surveillance services. Following our meeting with the Nigerian Security and Civic Defence Corps (NSCDC) Law Reform Committee, where we provided training on the need to regulate and oversee the private surveillance services provided by private security companies, the Committee introduced into the new draft of the Nigeria Private Security Industry Bill 2024 new powers to regulate and oversee private surveillance.
## **Strengthening guidance on innovations.**
- The UK Information Commissioner’s Office response to the consultation series on generative AI improved on their prior statements; and the adjustments reflect our submissions.
- • In December 2024, the European Data Protection Board (EDPB) adopted an opinion on AI models, and contains alignments with our submission, for instance, around stronger remedies.
## **Informing emerging global standards.**
- The UN Special Rapporteur on Terrorism echoed our concerns for the need for stronger effective regulation on surveillance technologies, including Facial Recognition Technologies and spyware, need for due diligence of state and private companies use of these technologies.
- Following our submission to the Office of the United Nations High Commissioner for Human Rights, their “Strengthening Human Rights in Counter-Terrorism Strategy and Policy” toolkit contains a separate section on the right to privacy with direct reflections of the content from our submission.
- • The report of the UN Secretary General on human rights in the administration of justice references our research positions that digital surveillance is increasingly leading to activists and protesters being subjected to criminal sanctions and proceedings. The report recommendations mirror several of our briefing points including around the right to fair trial.
- The World Health Organization’s technical brief on AI in sexual and reproductive health incorporated our comments and referenced our input.
- The UN Special Rapporteur on racism’s report on AI and racial discrimination referenced our demands around AI-enabled medical devices, data problems, and disease detection; and facial recognition technology impacts on racialised and marginalised communities, and in educational institutions.
- The UN resolution on the right to privacy in the digital age includes some of our demands (with Article 19) but is incomplete. The adopted resolution contains new language on AI and on data protection. It does not, however, include our suggestions on Social Media Intelligence.
## **4. Mobilising and amplifying others**
PI has a deep sense of responsibility for the field. We remember when the field was non-existent, under-funded, and struggling to be heard. We want a capable and sustainable sector. PI convenes a network of organisations from across the world, primarily in eastern Africa, Latin America, and South and South-east Asia.
Below are examples of results arising from our financial support to partners.
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**Privacy International**
## **Trustees’ annual report**
## **For the year ended 31 January 2025**
## **Valued voices and contributors**
- ICJ Kenya gauged awareness of government officials, journalists, and lawyers regarding WorldCoin through a series of workshops and presenting at the Annual Jurists Conference in India, attended by leading judges and legal practitioners.
- La Red en Defensa de los Derechos Digitales (R3D) in Mexico crafted resources around data and elections. Their “Censura Electoral” website has been intensively used by media and academics and praised by the sector.
- Transparencia Electoral improved privacy knowledge of Election Management Bodies and international and ’
- domestic election monitors through their Program on the NDI s OpenEDx platform. Their index and legal analyses on the protection of personal data with particular emphasis on the electoral contexts of 16 countries, informed conversations across the sector.
- Karisma developed a comprehensive database of open-source intelligence technology providers in Colombia, informing research by civil society, academia and journalists. Also our joint work with Karisma resulted in the UN Special Rapporteur on extreme poverty and human rights highlighting a government’s social registration programme’s impact on poverty and inequality.
## **Identifying essential change**
- Centre for Internet & Society in India, in consultation with others, developed advocacy points around better regulation of health data in India. Their analysis of mental health apps used in India identified existing apps security vulnerabilities and unauthorised data sharing with third parties.
- Following input from Data Privacy Brazil, the Brazilian Superior Electoral Court (TSE)’s Resolution on electoral propaganda adopted additional safeguards around transparency requirements for campaigns, candidates and political parties. They also developed an influential report presenting their research findings about AI in the Brazilian Elections.
- Digital Rights Foundation provided input into Pakistan’s Personal Data Protection Bill (through submission and direct engagement with Ministry of IT and Telecom and other stakeholders). They also actively informed the broader public about the bill and data protection rights, as part of their #PrivacyIsARight campaign. They also exposed technology-based abuses in Elections, providing some meaningful recommendations.
- InternetLab, based on their research, developed an analytical framework to address the intersection of education and technology in Brazil. They also attracted broader attention on automated decision-making within the CadÚnico system, through their report and its active involvement in various national and international fora.
- Haki Na Sheria took forward their litigation on Maisha Namba, Kenya’s national registration system. We joined the NIIMS coalition to keep updated with advocacy efforts in Kenya.
## **Strengthened organisations**
- With our support, the Privacy.PH Collective has been established to promote the privacy agenda in Philippines. So far the collective raised public awareness on visual surveillance technologies and organised a national forum on AI in Philippine elections.
- 7amleh in Israel-Palestine rebuilt their human resources system and developed a Monitoring & Evaluation system, moving from project-based to an organisation-level framework.
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**Privacy International**
## **Trustees’ annual report**
## **For the year ended 31 January 2025**
It is worth mentioning that partner organisations relied on PI’s materials and positions in planning and delivering of their work. As examples, Transparencia Electoral’s index is based on PI’s elections checklist; Karisma’s engagement with the UN Special Rapporteur was planned and crafted with our support.
## Financial review
## **Results for the year**
The results of the period and financial position of the charity are shown in the annexed financial statements.
Expenditure for the year increased to £2.12m (2023/2024: £2.07m) mostly as a result of changes to staff costs, and bringing the organisation’s work with overseas allies to pre-pandemic levels.
The incoming resources for the year were £2.42m (2023/2024: £2.59m) – the income in 2024/2025 reflects multi-year grant agreements in support of the organisational strategy (2023-2026) and new project support grants, received in second half of 2024.
The total funds of the charity at the end of the year were £3.64m. This included £1.3m in project and other restricted funds and £2.34m in unrestricted funds. The trustees have set aside £1.52m as Strategic fund 2026 of unrestricted funds as designated funds for delivery of the strategic objectives, projects and activities. The Trustees expect these designated funds to be fully utilised by the end of the strategic plan (2026). There is also £29k of designated fixed assets funds. The remaining £791k are general funds held for operational working capital requirements to address financial risks surrounding income and expenditure in line with the reserves policy set out below.
## Reserves policy and going concern
Taking into account the risks, funding sources, and complexity of Privacy International, the Board of Trustees has set a reserves policy for Privacy International aiming for unrestricted and undesignated reserves equivalent to 6 months’ running costs – resulting in a target of £840k (currently: £792k, constituting 5.1 months of operational costs, representing
the amount of general reserves not designated or otherwise committed to activity expenditure in 2025-2026).
The Executive Director and Resources Director continue to work with the Board of Trustees to maintain a policy of increasing unrestricted reserves until they are built to a level that ensures that core activity could continue during a period of unforeseen financial difficulty.
After making appropriate enquiries, the Trustees have a reasonable expectation that the company has adequate
resources to continue in operational existence for the foreseeable future. For this reason, they continue to adopt the going concern basis in preparing the financial statements.
## Fundraising
PI is working hard to ensure that our work is independent, cutting-edge and can be sustained for years to come. As a result, PI is funded by a variety of different sources. We do not accept funding from corporations because we believe that it would jeopardise the independence of our activities.
Main sources of funding for PI are multi-year grants (core support and project support alike) from a small number of big institutional donors. Public donations remain around 1% of overall annual income, which we continue to work to change with the goal of diversifying the funding to move away from high dependency on limited number of donors.
The staff and Board of Trustees of Privacy International are extremely grateful to the following organisations for their support over the past year:
Ford Foundation
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**Privacy International**
## **Trustees’ annual report**
## **For the year ended 31 January 2025**
Luminate Oak Foundation Open Society Foundations Paul Hamlyn Foundation Swedish International Development Cooperation Agency GNP+.
## **Volunteers and pro bono support**
The Trustees also wish to record their appreciation to the many eminent lawyers who have contributed their expertise to our legal work. We hugely appreciate the support received from Blackstone Chambers, Matrix Chambers, Doughty Street Chambers, Bhatt Murphy, Leigh Day, Deighton Pierce Glynn, Duncan Lewis, Covington & Burling LLP, independent counsel, and various university departments, law clinics and legal experts including at the Harvard Law School Cyberlaw Clinic and the University of Law Human Rights and Technology Research Clinic.
We also remain extremely grateful to Covington & Burling LLP for their continued support for Privacy International’s organisational development, including pro bono support for the further professionalization of our systems and processes for staffing and governance.
## Plans for the future
In 2025 we will continue our Strategic Interventions in each of our four ‘Strategic Area’ programmes. Additionally, we have set objectives around expanding our skills and capacities, deepening our expertise within core functions, and exploring more resilient operations.
## Structure, governance and management
The organisation is a charitable company limited by guarantee, incorporated on 16 January 2002 and registered as a charity on 26 May 2012.
The company was established under a memorandum of association which established the objects and powers of the charitable company and is governed under its articles of association.
Privacy International’s governing body is the Board of Trustees, which meets up to four times a year. The primary responsibility of the Board is to provide strategic leadership, set overall policy, regularly evaluate the charity's performance and risk management, and ensure compliance with UK law. The Board of Trustees delegates day-to-day management of the charity to the Executive Director.
All trustees give their time voluntarily and receive no benefits from the charity. Any expenses reclaimed from the charity are set out in note 6 to the accounts.
## **Financial controls**
Privacy International continues to strengthen its financial management systems. As the organisation grows, we work to ensure that PI is accountable to the public, our partners, and our funders.
All expenditure is carried out with reference to PI’s multi-year strategic plan and annual workplan, as approved by the Board prior to the start of each fiscal year. Financial procedures have been developed to monitor and evaluate the charity’s finances, including quarterly management accounts, which are prepared for review by Trustees, prior to each meeting of the Board.
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**Privacy International**
## **Trustees’ annual report**
## **For the year ended 31 January 2025**
The Board is assisted in taking decisions relating to budgeting and forecasting by the Finance and Audit Committee, which consists of at least two Trustees including the Treasurer. The Committee is responsible for recommending finance management policy to the Board and ensuring that existing policies are implemented. The audit function of the Committee is to consider the adequacy of risk management, internal controls, and governance.
## **Risk statement**
Privacy International takes seriously the safety, security and wellbeing of its staff, consultants, partners and contracted sources and researchers and fully accepts our duty to provide a reasonable standard of care to those performing activities on our behalf. Our mission and operating locations inherently mean that our staff, consultants, partners, contracted sources and researchers are exposed to safety and security risks. Our approach to risk is one of risk management rather than risk aversion; however, we do not seek to engage in high-risk activities.
PI’s risk register has been developed with reference to the UK Charity Commission and National Audit Office guidance and UK Charity Law and is regularly updated and comprehensively reviewed annually by the Board. We also have a whistleblowing policy in place.
PI reviews and updates its risk framework and risk register on a regular basis. The Board considers the following risks as having the greatest overall potential impact on PI as at the date of signing the Accounts.
## **1. Insufficiently diverse or unsustainable sources of funding**
The focus of policy makers and funders is continuously shifting to meet emerging challenges in ongoing multiple global crises.
PI remains highly reliant on limited number of funders - our most substantive long-term support comes from 4-5 institutional funders, and PI is vulnerable to their strategic changes. The board recognises the lack of flexibility in funding might result in limited resources to respond to unexpected project developments and/or crisis situations.
## What is PI doing about it?
PI is coping well, with a strong cash position at the end of fiscal year.
The Executive Director, with the support of the Strategy Team, engages regularly with current PI funders, not only as it relates to financial support but also to make sure they have in-depth understanding of and commitment to issues the sector is tackling and facing. PI regularly reviews the strategic developments of current and potential funders and keeps exploring relationships with other funders in the domain. The executive team also provides regular updates to the Finance and Audit Committee and Board of Trustees.
We also continue to build infrastructure and processes to increase income from the public.
We are working to develop a diverse income portfolio that reduces risk exposure (especially risk of starvation cycle) and dependency on limited number of funding sources, without jeopardising its independence. With a focus on critical operating reserves, PI will also work to ensure the funding structure considers building capital to allow for investment to support further development (i.e. explore new domains and methods).
## **2. Organisational health**
PI transitioned to a new strategic plan in 2023 in a climate of significant external pressures. We need to ensure that the organisation is capable of navigating and responding to these challenges.
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## **Trustees’ annual report**
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## What is PI doing about it?
In 2023 PI deployed a new updated staff handbook, after a comprehensive review. We also updated our wellbeing procedure. Staff who feel supported will in return contribute to a balanced and healthy workplace.
Since 2023, Line Managers receive continuous HR training and support. In 2024 this covered performance management and improvement. And Programme Leads receive advanced training and coaching on having challenging conversations.
We updated our Global Risk Framework (policy and accompanying procedures) and revised our organisational risk register, adding context to external pressures and world events affecting our operational considerations. We also updated our anti-bribery and corruption documents and guidance.
Though we were surprised when the Russian Government imposed sanctions on individual members of PI staff in August 2024, our Risk Framework was effective and useful, giving us the tools to adapt and respond.
## Appointment of trustees
At any one time the number of Trustees shall not be less than five, and no more than twelve. New Trustees are recruited through an open application process. Appointments are made not only on the basis of individual merit, but also taking into consideration the existing expertise and experience of the Trustees.
## Trustee induction and training
New Trustees receive information on Privacy International's work, their duties as Trustees, and take part in induction meetings with the Executive Director and other members of the Privacy International staff.
## Remuneration policy for key management personnel
The remuneration of staff is guided by PI’s Values and Competency Framework as set out in the organisational Staff Handbook, outlining roles and responsibilities, ensuring that each employee is rewarded in line with the level of their role and our overall remuneration structure. The remuneration of the Executive Director is decided by the Board of Trustees.
## Statement of responsibilities of the trustees
The trustees (who are also directors of Privacy International for the purposes of company law) are responsible for preparing the trustees’ annual report and the financial statements in accordance with applicable law and United Kingdom Accounting Standards (United Kingdom Generally Accepted Accounting Practice).
Company law requires the trustees to prepare financial statements for each financial year which give a true and fair view of the state of affairs of the charitable company and of the incoming resources and application of resources, including the income and expenditure, of the charitable company for that period. In preparing these financial statements, the trustees are required to:
- Select suitable accounting policies and then apply them consistently
- Observe the methods and principles in the Charities SORP
- Make judgements and estimates that are reasonable and prudent
- State whether applicable UK Accounting Standards and statements of recommended practice have been followed, subject to any material departures disclosed and explained in the financial statements
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**Privacy International**
## **Trustees’ annual report**
## **For the year ended 31 January 2025**
- Prepare the financial statements on the going concern basis unless it is inappropriate to presume that the charity will continue in operation.
The trustees are responsible for keeping adequate accounting records that disclose with reasonable accuracy at any time the financial position of the charitable company and enable them to ensure that the financial statements comply with the Companies Act 2006. They are also responsible for safeguarding the assets of the charitable company and hence for taking reasonable steps for the prevention and detection of fraud and other irregularities.
In so far as the trustees are aware:
- There is no relevant audit information of which the charitable company’s auditor is unaware
- The trustees have taken all steps that they ought to have taken to make themselves aware of any relevant audit information and to establish that the auditor is aware of that information
The trustees are responsible for the maintenance and integrity of the corporate and financial information included on the charitable company's website. Legislation in the United Kingdom governing the preparation and dissemination of financial statements may differ from legislation in other jurisdictions.
Members of the charity guarantee to contribute an amount not exceeding £1 to the assets of the charity in the event of winding up. The total number of such guarantees at 31 January 2025 was 8 (2024: 7). The trustees are members of the charity but this entitles them only to voting rights. The trustees have no beneficial interest in the charity.
## Auditor
Sayer Vincent LLP was re-appointed as the charitable company's auditor during the year and has expressed its willingness to continue in that capacity.
The trustees’ annual report has been approved by the trustees on 15 September 2025 and signed on their behalf by:
Joshua Castellino
Chair of the Board
13
**Independent auditor’s report**
## **to the members of**
## **Privacy International**
## Opinion
We have audited the financial statements of Privacy International (the ‘charitable company’) for the year ended 31 January 2025 which comprise the statement of financial activities, balance sheet, statement of cash flows and notes to the financial statements, including significant accounting policies. The financial reporting framework that has been applied in their preparation is applicable law and United Kingdom Accounting Standards, including FRS 102 The Financial Reporting Standard applicable in the UK and Republic of Ireland (United Kingdom Generally Accepted Accounting Practice).
- In our opinion, the financial statements:
- Give a true and fair view of the state of the charitable company’s affairs as at 31 January 2025 and of its incoming resources and application of resources, including its income and expenditure for the year then ended
- Have been properly prepared in accordance with United Kingdom Generally Accepted Accounting Practice
- Have been prepared in accordance with the requirements of the Companies Act 2006
## Basis for opinion
We conducted our audit in accordance with International Standards on Auditing (UK) (ISAs (UK)) and applicable law. Our responsibilities under those standards are further described in the Auditor’s responsibilities for the audit of the financial statements section of our report. We are independent of the charitable company in accordance with the ethical requirements that are relevant to our audit of the financial statements in the UK, including the FRC’s Ethical Standard and we have fulfilled our other ethical responsibilities in accordance with these requirements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
## Conclusions relating to going concern
In auditing the financial statements, we have concluded that the trustees' use of the going concern basis of accounting in the preparation of the financial statements is appropriate.
Based on the work we have performed, we have not identified any material uncertainties relating to events or conditions that, individually or collectively, may cast significant doubt on Privacy International's ability to continue as a going concern for a period of at least twelve months from when the financial statements are authorised for issue.
Our responsibilities and the responsibilities of the trustees with respect to going concern are described in the relevant sections of this report.
14
**Independent auditor’s report**
## **to the members of**
## **Privacy International**
## Other Information
The other information comprises the information included in the trustees’ annual report, other than the financial statements and our auditor’s report thereon. The trustees are responsible for the other information contained within the annual report. Our opinion on the financial statements does not cover the other information and, except to the extent otherwise explicitly stated in our report, we do not express any form of assurance conclusion thereon. Our responsibility is to read the other information and, in doing so, consider whether the other information is materially inconsistent with the financial statements or our knowledge obtained in the course of the audit, or otherwise appears to be materially misstated. If we identify such material inconsistencies or apparent material misstatements, we are required to determine whether this gives rise to a material misstatement in the financial statements themselves. If, based on the work we have performed, we conclude that there is a material misstatement of this other information, we are required to report that fact.
We have nothing to report in this regard.
## Opinions on other matters prescribed by the Companies Act 2006
In our opinion, based on the work undertaken in the course of the audit:
- The information given in the trustees’ annual report, for the financial year for which the financial statements are prepared is consistent with the financial statements; and
- The trustees’ annual report, has been prepared in accordance with applicable legal requirements.
## Matters on which we are required to report by exception
In the light of the knowledge and understanding of the charitable company and its environment obtained in the course of the audit, we have not identified material misstatements in the trustees’ annual report. We have nothing to report in respect of the following matters in relation to which the Companies Act 2006 requires us to report to you if, in our opinion:
- Adequate accounting records have not been kept, or returns adequate for our audit have not been received from branches not visited by us; or
- The financial statements are not in agreement with the accounting records and returns; or
- Certain disclosures of trustees’ remuneration specified by law are not made; or
- We have not received all the information and explanations we require for our audit; or
- The directors were not entitled to prepare the financial statements in accordance with the small companies regime and take advantage of the small companies’ exemptions in preparing the trustees’ annual report and from the requirement to prepare a strategic report.
## Responsibilities of trustees
As explained more fully in the statement of trustees’ responsibilities set out in the trustees’ annual report, the trustees (who are also the directors of the charitable company for the purposes of company law) are responsible
15
**Independent auditor’s report**
## **to the members of**
## **Privacy International**
for the preparation of the financial statements and for being satisfied that they give a true and fair view, and for such internal control as the trustees determine is necessary to enable the preparation of financial statements that are free from material misstatement, whether due to fraud or error.
In preparing the financial statements, the trustees are responsible for assessing the charitable company’s ability to continue as a going concern, disclosing, as applicable, matters related to going concern and using the going concern basis of accounting unless the trustees either intend to liquidate the charitable company or to cease operations, or have no realistic alternative but to do so.
## Auditor’s responsibilities for the audit of the financial statements
Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance but is not a guarantee that an audit conducted in accordance with ISAs (UK) will always detect a material misstatement when it exists. Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.
Irregularities, including fraud, are instances of non-compliance with laws and regulations. We design procedures in line with our responsibilities, outlined above, to detect material misstatements in respect of irregularities, including fraud. The extent to which our procedures are capable of detecting irregularities, including fraud are set out below.
## Capability of the audit in detecting irregularities
In identifying and assessing risks of material misstatement in respect of irregularities, including fraud and noncompliance with laws and regulations, our procedures included the following:
- We enquired of management and Finance and Audit committee, which included obtaining and reviewing supporting documentation, concerning the charity’s policies and procedures relating to:
- Identifying, evaluating, and complying with laws and regulations and whether they were aware of any instances of non-compliance;
- Detecting and responding to the risks of fraud and whether they have knowledge of any actual, suspected, or alleged fraud;
- The internal controls established to mitigate risks related to fraud or non-compliance with laws and regulations.
- We inspected the minutes of meetings of those charged with governance.
- We obtained an understanding of the legal and regulatory framework that the charity operates in, focusing on those laws and regulations that had a material effect on the financial statements or that had a fundamental effect on the operations of the charity from our professional and sector experience.
- We communicated applicable laws and regulations throughout the audit team and remained alert to any indications of non-compliance throughout the audit.
16
**Independent auditor’s report**
## **to the members of**
## **Privacy International**
- We reviewed any reports made to regulators.
- We reviewed the financial statement disclosures and tested these to supporting documentation to assess compliance with applicable laws and regulations.
- We performed analytical procedures to identify any unusual or unexpected relationships that may indicate risks of material misstatement due to fraud.
- In addressing the risk of fraud through management override of controls, we tested the appropriateness of journal entries and other adjustments, assessed whether the judgements made in making accounting estimates are indicative of a potential bias and tested significant transactions that are unusual or those outside the normal course of business.
Because of the inherent limitations of an audit, there is a risk that we will not detect all irregularities, including those leading to a material misstatement in the financial statements or non-compliance with regulation. This risk increases the more that compliance with a law or regulation is removed from the events and transactions reflected in the financial statements, as we will be less likely to become aware of instances of non-compliance. The risk is also greater regarding irregularities occurring due to fraud rather than error, as fraud involves intentional concealment, forgery, collusion, omission or misrepresentation.
A further description of our responsibilities is available on the Financial Reporting Council’s website at: www.frc.org.uk/auditorsresponsibilities _._ This description forms part of our auditor’s report.
## Use of our report
This report is made solely to the charitable company's members as a body, in accordance with Chapter 3 of Part 16 of the Companies Act 2006. Our audit work has been undertaken so that we might state to the charitable company's members those matters we are required to state to them in an auditor’s report and for no other purpose. To the fullest extent permitted by law, we do not accept or assume responsibility to anyone other than the charitable company and the charitable company's members as a body, for our audit work, for this report, or for the opinions we have formed.
Noelia Serrano (Senior statutory auditor)
## 15 September 2025
for and on behalf of Sayer Vincent LLP, Statutory Auditor
110 Golden Lane, LONDON, EC1Y 0TG
17
## **Privacy International**
**Statement of financial activities** (incorporating an income and expenditure account)
## **For the year ended 31 January 2025**
|**For theyear ended 31 January 2025**|||||||
|---|---|---|---|---|---|---|
|Note
**Income from:**
2
3
5
14
**Rec**Auditor's remuneration (gross of VAT):
Charitable activities
**Total expenditure**
Donations and legacies
Charitable activities
Investments
**Total income**
**Expenditure on:**
Other income
**Total funds brought forward**
**Net income for the year**
**Total funds carried forward**
Transfers between funds
**Net movement in funds**|Unrestricted
£
27,969
564,199
3,501
31,085|Restricted
£
-
1,794,342
-
-|**2025**
**Total**
**£**
**27,969**
**2,358,541**
**3,501**
**31,085**|Unrestricted
£
100,759
1,682,338
13,141
6,128|Restricted
£
-
792,149
-
-|2024
Total
£
100,759
2,474,487
13,141
6,128|
||626,754|1,794,342|**2,421,096**|1,802,366|792,149|2,594,515|
||1,203,707|915,144|**2,118,851**|1,223,004|849,466|2,072,470|
||1,203,707|915,144|**2,118,851**|1,223,004|849,466|2,072,470|
||(576,953)
(13)|879,198
13|302,245
**-**|579,362
66|(57,317)
(66)|522,045
-|
||(576,966)
2,914,400|879,211
423,695|**302,245**
**3,338,095**|579,428
2,334,972|(57,383)
481,078|522,045
2,816,050|
||2,337,434|1,302,906|**3,640,340**|2,914,400|423,695|3,338,095|
All of the above results are derived from continuing activities. There were no other recognised gains or losses other than those stated above. Movements in funds are disclosed in Note 14a to the financial statements.
18
Company no. 4354366
## **Privacy International**
**Statement of financial activities** (incorporating an income and expenditure account)
## **As at 31 January 2025**
|Note
**£**
**Fixed assets:**
10
**Current assets:**
11
**57,263**
**3,670,095**
**3,727,358**
**Liabilities:**
12
**(116,377)**
14a
**1,545,863**
**791,571**
Unrestricted general funds
General funds
**Total charity funds**
Cash at bank and in hand
Tangible assets
**The funds of the charity:**
Creditors: amounts falling due within one year
**Net current assets**
**Total net assets**
Debtors
Restricted income funds
Unrestricted income funds:
Designated funds|Note
**£**
**Fixed assets:**
10
**Current assets:**
11
**57,263**
**3,670,095**
**3,727,358**
**Liabilities:**
12
**(116,377)**
14a
**1,545,863**
**791,571**
Unrestricted general funds
General funds
**Total charity funds**
Cash at bank and in hand
Tangible assets
**The funds of the charity:**
Creditors: amounts falling due within one year
**Net current assets**
**Total net assets**
Debtors
Restricted income funds
Unrestricted income funds:
Designated funds|**2025**
**£**
**29,359**|£
58,760
3,418,976|2024
£
31,240|
|---|---|---|---|---|
|||**29,359**
**3,610,981**||31,240
3,306,855|
||**3,727,358**
**(116,377)**||3,477,736
(170,881)||
||**1,545,863**
**791,571**||2,186,402
727,998||
|||**3,640,340**||3,338,095|
|||**1,302,906**
**2,337,434**||423,695
2,914,400|
||||||
|||**3,640,340**||3,338,095|
Approved by the trustees on 15 September 2025 and signed on their behalf by
Professor Joshua Castellino Trustee
19
## **Privacy International**
**Statement of financial activities** (incorporating an income and expenditure account)
## **For the year ended 31 January 2025**
|**Cash flows from operating activities**
(as per the statement of financial activities)
Depreciation charges
Dividends, interest and rent from investments
Increase in debtors
(Decrease)/Increase in creditors
Auditor's remuneration (gross of VAT):
Cash at bank and in hand
Purchase of fixed assets
**Net cash provided by operating activities**
**Analysis of cash and cash equivalents and of net debt**
Net income for the reporting period
**Cash and cash equivalents at the end of the year**
**Change in cash and cash equivalents in the year**
Cash and cash equivalents at the beginning of the year
**Net cash provided by/(used in) investing activities**
**Cash flows from investing activities:**
Dividends, interest and rents from investments|**£**
**302,245**
**16,600**
**(31,085)**
**1,497**
**(54,504)**
**31,085**
**(14,719)**|**£**
**2025**|£
522,045
31,041
(6,128)
39,470
54,717
6,128
(28,766)|£
2024|
|---|---|---|---|---|
|||**234,753**
**16,366**
**251,119**
**3,418,976**||641,145
(22,638)
618,507
2,800,469|
||At 1 February
2024
£
3,418,976||Other non-cash
changes
£
-||
|||**3,670,095**||3,418,976|
|||
Cash flows
£
251,119||
**At 31 January**
**2025**
**£**
**3,670,095**|
||3,418,976|251,119|-|**3,670,095**|
20
**Privacy International**
**Notes to the financial statements**
## **For the year ended 31 January 2025**
## **1 Accounting policies**
## **a) Statutory information**
Privacy International is a charitable company limited by guarantee and is incorporated in England & Wales.
The registered office address and principal place of business is 62 Britton Street, London, EC1M 5UY.
## **b) Basis of preparation**
The financial statements have been prepared in accordance with Accounting and Reporting by Charities: Statement of Recommended Practice applicable to charities preparing their accounts in accordance with the Financial Reporting Standard applicable in the UK and Republic of Ireland (FRS 102) - (Charities SORP FRS 102), The Financial Reporting Standard applicable in the UK and Republic of Ireland (FRS 102) and the Companies Act 2006/Charities Act 2011.
Assets and liabilities are initially recognised at historical cost or transaction value unless otherwise stated in the relevant accounting policy or note.
In applying the financial reporting framework, the trustees have made a number of subjective judgements, for example in respect of significant accounting estimates. Estimates and judgements are continually evaluated and are based on historical experience and other factors, including expectations of future events that are believed to be reasonable under the circumstances. The nature of the estimation means the actual outcomes could differ from those estimates. Any significant estimates and judgements affecting these financial statements are detailed within the relevant accounting policy below.
## **c) Public benefit entity**
The charity meets the definition of a public benefit entity under FRS 102.
## **d) Going concern**
The charity's income is mainly derived from non self-generated sources, such as grants, service level agreements and other governmental or NGO sources. The trustees consider that there are no material uncertainties about the likelihood that this support will continue, and accordingly, the accounts have been prepared on a going concern basis.
## **e) Income**
Income is recognised when the charity has entitlement to the funds, any performance conditions attached to the income have been met, it is probable that the income will be received and that the amount can be measured reliably.
Income from government and other grants, whether ‘capital’ grants or ‘revenue’ grants, is recognised when the charity has entitlement to the funds, any performance conditions attached to the grants have been met, it is probable that the income will be received and the amount can be measured reliably and is not deferred.
## **f) Donations of gifts, services and facilities**
Donated professional services and donated facilities are recognised as income when the charity has control over the item or received the service, any conditions associated with the donation have been met, the receipt of economic benefit from the use by the charity of the item is probable and that economic benefit can be measured reliably. In accordance with the Charities SORP (FRS 102), volunteer time is not recognised so refer to the trustees’ annual report for more information about their contribution.
On receipt, donated gifts, professional services and donated facilities are recognised on the basis of the value of the gift to the charity which is the amount the charity would have been willing to pay to obtain services or facilities of equivalent economic benefit on the open market; a corresponding amount is then recognised in expenditure in the period of receipt.
21
**Privacy International**
**Notes to the financial statements**
## **For the year ended 31 January 2025**
## **1 Accounting policies (continued)**
## **g) Interest receivable**
Interest on funds held on deposit is included when receivable and the amount can be measured reliably by the charity; this is normally upon notification of the interest paid or payable by the bank.
## **h) Fund accounting**
Restricted funds are to be used for specific purposes as laid down by the donor. Expenditure which meets these criteria is charged to the fund.
Unrestricted funds are donations and other incoming resources received or generated for the charitable purposes. Designated funds are unrestricted funds earmarked by the trustees for particular purposes.
## **i) Expenditure recognition**
Expenditure is recognised once there is a legal or constructive obligation to make a payment to a third party, it is probable that settlement will be required and the amount of the obligation can be measured reliably. Irrecoverable VAT is charged as a cost against the activity for which the expenditure was incurred. Expenditure is classified under the following activity headings:
Expenditure included in Raising Funds includes amounts incurred in obtaining grants and other donations.
Charitable expenditure includes those costs expended in fulfilling the charity's principal objects, as outlined in the Report of the Trustees. These include grants payable, governance costs and an apportionment of support costs.
- Grants payable are payments made to third parties in furtherance of the charity's objects. In the case of an unconditional grant offer this is accrued once the recipient has been notified of the grant award. The notification
- * gives the recipient a reasonable expectation that they will receive the grant. Grants awards that are subject to the recipient fulfilling performance conditions are only accrued when the recipient has been notified of the grant and any remaining unfulfilled condition attaching to that grant is outside of the control of the charity.
- Governance costs comprise all costs involving the public accountability of the charity and its compliance with
- * regulation and good practice. These costs include costs related to the independent examination and legal fees.
- Rentals under operating leases are charged as incurred over the term of the lease.
Costs are allocated directly to projects where they can be identified as relating solely to that project. Other costs are allocated between the funds based on staff time spent on the fund activities or other appropriate criteria. Irrecoverable VAT is charged as a cost against the activity for which the expenditure was incurred.
## **Allocation of support costs**
Support costs are allocated to the charity's charitable activities.
Governance costs are the costs associated with the governance arrangements of the charity. These costs are associated with constitutional and statutory requirements and include any costs associated with the strategic management of the charity’s activities.
22
**Privacy International**
**Notes to the financial statements**
## **For the year ended 31 January 2025**
## **1 Accounting policies (continued)**
## **j) Tangible fixed assets**
Tangible fixed assets are stated at cost less depreciation. Depreciation is provided at the following annual rates in order to write off each asset over its estimated useful life.
Tangible fixed assets are capitalised where the purchase price exceeds £250 with expected life and/or economic benefit of longer than 1 year.
Depreciation is provided at rates calculated to write down the cost of each asset to its estimated residual value over its expected useful life. The depreciation rates in use are as follows:
|*|Software|33% on cost|
|---|---|---|
|*|Computer equipment|50% on cost|
|*|Furniture & fixtures|25% on cost|
|*|Leasehold improvements|20% on cost|
## **k) Debtors**
Trade and other debtors are recognised at the settlement amount due after any trade discount offered. Prepayments are valued at the amount prepaid net of any trade discounts due.
## **l) Cash at bank and in hand**
Cash at bank and cash in hand includes cash and short term highly liquid investments with a short maturity of three months or less from the date of acquisition or opening of the deposit or similar account.
## **m) Creditors and provisions**
Creditors and provisions are recognised where the charity has a present obligation resulting from a past event that will probably result in the transfer of funds to a third party and the amount due to settle the obligation can be measured or estimated reliably. Creditors and provisions are normally recognised at their settlement amount after allowing for any trade discounts due.
## **n) Financial instruments**
The charity only has financial assets and financial liabilities of a kind that qualify as basic financial instruments. Basic financial instruments are initially recognised at transaction value and subsequently measured at their settlement value.
## **o) Pensions**
The charity operates defined contribution schemes which are administered by outside independent pensions providers. Contributions payable for the year are charged to the Statement of Financial Activities.
23
**Privacy International**
## **Notes to the financial statements**
## **For the year ended 31 January 2025**
## **2 Income from charitable activities**
|Foundation to Promote
Open Society
Oak Foundation
The Swedish International
Development Cooperation
Agency - Core support
Ford Foundation BUILD
Paul Hamlyn Foundation
Luminate
Ford Foundation BUILD
Donated in-kind services
Ford Foundation - project
GNP+
**Grants**|Unrestricted
£
-
350,000
-
195,162
19,037
-
-
-
-
-|£
-
-
1,151,714
-
-
-
130,108
408,998
-
103,522
Restricted|**2025**
**Total**
**£**
**-**
**350,000**
**1,151,714**
**195,162**
**19,037**
**-**
**130,108**
**408,998**
**-**
**103,522**|Unrestricted
£
819,068
250,000
351,309
243,540
18,420
-
-
-
-
-|£
-
-
-
-
-
164,400
162,360
406,389
59,000
-
Restricted|2024
Total
£
819,068
250,000
351,309
243,540
18,420
164,400
162,360
406,389
59,000
-|
|---|---|---|---|---|---|---|
||**564,199**|**1,794,342**|**2,358,541**|1,682,338|792,149|2,474,487|
24
**Privacy International**
## **Notes to financial statements**
## **For the year ended 31 January 2025**
## **3a Analysis of expenditure (current year)**
|Staff costs (Note 6)
Other staff related costs
Grants to partners (note 4)
Project expenses
Rent
Depreciation
Consultancy
Trustee expenses
Audit
(Gains) on foreign exchange
Office expenses
Legal and professional fees
Travel and accommodation
Translation
Other costs
Support costs
Governance costs
**Total expenditure 2025**
Total expenditure 2024|Charitable
Activities
£
1,440,427
39,630
198,182
84,712
-
-
56,210
-
-
(82)
-
4,212
36,256
3,606
615
1,863,768
237,620
17,463
**2,118,851**
2,072,470|Governance
costs
£
-
-
-
-
-
-
-
3,065
14,364
-
-
-
-
-
34
17,463
-
(17,463)
**-**
-|Support
costs
£
-
-
-
-
93,460
16,600
-
-
-
-
108,523
19,037
-
-
-
237,620
(237,620)
-
**-**
-|**2025**
**Total**
**£**
**1,440,427**
**39,630**
**198,182**
**84,712**
**93,460**
**16,600**
**56,210**
**3,065**
**14,364**
**(82)**
**108,523**
**23,249**
**36,256**
**3,606**
**649**
**2,118,851**
**-**
**-**
**2,118,851**|2024
Total
£
1,396,855
60,006
99,951
55,600
85,468
31,041
106,656
4,430
15,330
(271)
116,633
27,734
64,804
6,827
1,405|
|---|---|---|---|---|---|
||||||2,072,470
-
-|
||||||**-**|
||||||2,072,470|
25
**Privacy International**
## **Notes to financial statements**
## **For the year ended 31 January 2025**
## **3b Analysis of expenditure (prior year)**
|Staff costs (Note 6)
Other staff related costs
Grants to partners (note 4)
Project expenses
Rent
Depreciation
Consultancy
Trustee expenses
Audit
(Gains) on foreign exchange
Office expenses
Legal and professional fees
Travel and accommodation
Translation
Other costs
Support costs
Governance costs
**Total expenditure 2024**|Charitable
Activities
£
1,396,855
60,006
99,951
55,600
-
-
106,656
-
-
(271)
-
9,494
64,804
6,827
-
1,799,922
252,774
19,773
**2,072,470**|Governance
costs
£
-
-
-
-
-
-
-
4,430
15,330
-
-
-
-
-
13
19,773
-
(19,773)
**-**|Support
costs
£
-
-
-
-
85,468
31,041
-
-
-
-
116,633
18,240
-
-
1,392
252,774
(252,774)
-
**-**|**2024**
**Total**
**£**
**1,396,855**
**60,006**
**99,951**
**55,600**
**85,468**
**31,041**
**106,656**
**4,430**
**15,330**
**(271)**
**116,633**
**27,734**
**64,804**
**6,827**
**1,405**|
|---|---|---|---|---|
|||||**2,072,470**
**-**
**-**|
|||||**2,072,470**|
26
**Privacy International**
## **Notes to financial statements**
## **For the year ended 31 January 2025**
## **4 Grant making to institutions**
|**Grant making to institutions**|||
|---|---|---|
|Other
Haki Na Sheria
At the end of the year
ICJ Kenya
Internet Labs
Paradigm Initiative Nigeria
Red en Defensa de los Derechos Civiles
Transparencia Electoral
Foundation for Media Alternatives
**Cost**
The Centre for Internet and Society
Fundación Karisma
Data Privacy Brazil
The Libertarian Research & Education Trust
Kenya Legal and Ethical issues network on HIV&AIDS
Unwanted Witness|**2025**
**£**
**12,652**
**2,500**
**19,955**
**-**
**4,000**
**20,000**
**29,300**
**819**
**2,773**
**-**
**34,504**
**10,071**
**2,000**
**59,608**|2024
£
-
-
-
10,000
-
-
14,201
8,000
24,953
5,000
11,501
8,072
5,000
13,225|
||**198,182**|99,951|
Other grants include grants to partners below £5,000 in the year and also those organisations which need to remain anonymous due to sensitive nature of their work.
## **5 Net income for the year**
This is stated after charging / (crediting):
|This is stated after charging / (crediting):|||
|---|---|---|
||**2025**|2024|
||**£**|£|
|Depreciation|**16,600**|31,041|
|Property|**88,069**|83,328|
|Auditor's remuneration (gross of VAT):|||
|Audit|**14,364**|13,680|
27
**Privacy International**
## **Notes to financial statements**
## **For the year ended 31 January 2025**
## **6 Analysis of staff costs, trustee remuneration and expenses, and the cost of key management personnel**
|Social security costs
Employer’s contribution to defined contribution pension schemes
Salaries and wages|**2025**
**£**
**1,203,040**
**133,705**
**103,682**|2024
£
1,174,686
127,343
94,826|
|---|---|---|
||**1,440,427**|1,396,855|
The following number of employees received employee benefits (excluding employer pension costs and employer's national insurance) during the year between:
|||**2025**|2024|
|---|---|---|---|
|||**No.**|No.|
|£60,000|- £69,999|**1**|1|
|£70,000|- £79,999|**-**|-|
|£80,000|- £89,999|**-**|1|
|£90,000|- £99,999|**1**|-|
The charity considers its key management personnel to be the trustees and the executive director. The total employment benefits (including employer pension contributions) of the key management personnel were £115,011 (2024: £109,475).
Included within salaries and wages are redundancy and termination costs totaling Nil (2024: £21,213)
No remuneration was paid to any trustee or their associates for services as a trustee during the year ended 31 January 2025 nor to 31 January 2024.
During the year the charity paid 3 trustees' travel expenses £3,065: (2024: £4,430).
## **7 Staff numbers**
The average number of employees (head count based on number of staff employed) during the year was 25 (2024: 25)
## **8 Related party transactions**
There are no related party transactions to disclose for this financial year (2024: none).
## **9 Taxation**
The company is a registered charity. Accordingly, it is exempt from taxation in respect of income and capital gains to the extent that these are applied to its charitable objects.
28
**Privacy International**
## **Notes to financial statements**
## **For the year ended 31 January 2025**
## **10 Tangible fixed assets**
|**Tangible fixed assets**|||||
|---|---|---|---|---|
|At the start of the year
At the start of the year
**Depreciation**
At the end of the year
At the start of the year
Additions in year
Disposals in year
Charge for the year
**Cost**
Eliminated on disposal
At the end of the year
**Net book value**
**At the end of the year**|Leasehold
improvements
Software
£
£
122,717
3,645
4,766
-
-
-|Computer
equipment
£
70,240
9,953
-|
Furniture &
fixtures
£
22,916
-
-|
**Total**
**£**
**219,518**
**14,719**
**-**|
||127,483
3,645|80,193|22,916|**234,237**|
||102,799
3,645
5,453
-
-
-|61,540
10,284
-|20,294
863
-|**188,278**
**16,600**
**-**|
||108,252
3,645|71,824|21,157|**204,878**|
||19,231
-|8,369|1,758|**29,359**|
||19,918
-|8,700|2,621|31,240|
All of the above assets are used for charitable purposes.
## **11 Debtors**
|Rent deposit
Prepayments|**2025**
**£**
**15,478**
**41,785**|2024
£
15,478
43,282|
|---|---|---|
||**57,263**|58,760|
## **12 Creditors: amounts falling due within one year**
|**Creditors: amounts falling due within one year**|||
|---|---|---|
|Accruals
Credit cards
Payroll taxes
Trade creditors|**2025**
**£**
**4,122**
**3,594**
**34,972**
**73,689**|2024
£
4,900
5,435
41,093
119,452|
||**116,377**|170,881|
29
**Privacy International**
## **Notes to financial statements**
## **For the year ended 31 January 2025**
## **13a Analysis of net assets between funds (current year)**
|**Analysis of net assets between funds (current year)**|||||
|---|---|---|---|---|
|**Analysis of net assets between funds (prior year)**
Tangible fixed assets
Current liabilities
**Net assets at 31 January 2024**
**Net assets at 31 January 2025**
Tangible fixed assets
Current liabilities
Current assets
Current assets|General
unrestricted
£
-
791,571
-|
Designated
£
29,359
1,632,881
(116,377)|Restricted
£
-
1,302,906
-|**Total funds**
**£**
**29,359**
**3,727,358**
**(116,377)**|
||**791,571**|**1,545,863**|**1,302,906**|**3,640,340**|
||General
unrestricted
£
-
727,998
-|
Designated
£
31,240
2,326,042
(170,880)|Restricted
£
-
423,695
-|**Total funds**
**£**
**31,240**
**3,477,735**
**(170,880)**|
||**727,998**|**2,186,402**|**423,695**|**3,338,095**|
## **13b Analysis of net assets between funds (prior year)**
30
**Privacy International**
## **Notes to financial statements**
## **For the year ended 31 January 2025**
## **14a Movements in funds (current year)**
|**Movements in funds (current year)**|||||
|---|---|---|---|---|
|**Total restricted funds**
Total designated funds
**General funds**
**Restricted funds:**
Ford Foundation
Ford Foundation BUILD
The Swedish International Development
Cooperation Agency - Core support
Designated funds:
Luminate Central Fund
2024 Activity fund
**Unrestricted funds:**
GNP+
Fixed asset fund
Strategic fund 2026
**Total unrestricted funds**
**Total funds**|At 1 February
2024 Income & gains
£
£
36,029
-
148,303
130,108
239,363
408,998
-
1,151,714
-
103,522|Expenditure
& losses
£
(36,033)
(122,789)
(648,370)
(40,818)
(67,133)|
Transfers
£
4
-
9
-
-|**At 31**
**January**
**2025**
**£**
**155,622**
**-**
**1,110,896**
**36,389**|
||423,695
1,794,342|(915,144)|13|**1,302,906**|
||525,912
-
1,629,250
545,162
31,240
-|(525,912)
(657,908)
-|-
-
(1,881)|**-**
**1,516,504**
**29,359**|
||2,186,402
545,162|(1,183,820)|(1,881)|**1,545,863**|
||727,998
81,592|(19,887)|1,868|**791,571**|
||2,914,400
626,754|(1,203,707)|(13)|**2,337,434**|
||3,338,094
2,421,096|(2,118,851)|-|**3,640,340**|
The narrative to explain the purpose of each fund is given at the foot of the note below.
31
**Privacy International**
## **Notes to financial statements**
## **For the year ended 31 January 2025**
## **14b Movements in funds (prior year)**
|**Total restricted funds**
Total designated funds
**General funds**
Ford Foundation BUILD
**Restricted funds:**
**Total funds**
Fixed asset fund
Paul Hamlyn Foundation
**Unrestricted funds:**
The Swedish International Development
Cooperation Agency - Core support
2024 Activitiy fund
Strategic fund 2026
Ford Foundation
**Total unrestricted funds**
Designated funds:|At 1 February
2023 Income & gains
£
£
14,505
164,400
95,589
162,360
350
59,000
370,634
406,389|Expenditure
& losses
£
(142,876)
(109,646)
(59,284)
(537,660)|
Transfers
£
-
-
(66)
-|**At 31**
**January**
**2024**
**£**
**36,029**
**148,303**
**239,363**|
|---|---|---|---|---|
||481,078
792,149|(849,466)|(66)|**423,695**|
||1,607,206
-
-
-
33,516
-|(1,081,294)
-
-|-
1,629,250
(2,276)|**525,912**
**1,629,250**
**31,240**|
||1,640,722
-|(1,081,294)|1,626,974|**2,186,402**|
||694,250
1,802,366|(141,710)|(1,626,908)|**727,998**|
||2,334,972
1,802,366|(1,223,004)|66|**2,914,400**|
||2,816,050
2,594,515|(2,072,470)|-|**3,338,095**|
## **Purposes of restricted funds**
Projects financed by restricted funds are supported by unrestricted funding where necessary. This occurs where the funding is in arrears or the incidence of expenditure on the project occurs disproportionately at the beginning of the project compared to the income flows. Where restricted projects end the year with a deficit, this is met by after year-end restricted income or transfers from unrestricted funds.
## **Ford Foundation**
The Ford Foundation is a globally oriented private foundation with the mission of advancing human welfare. In late 2020 Privacy International received a 2 year-grant to support civil society in the Global South to investigate, advocate against and support civil society in understanding implications of developments around global and local responses to COVID-19, extended into early 2024. In October 2020 PI received a five-year general support grant, combined with targeted organisational strengthening through Ford Foundation BUILD program.
## **Luminate**
Established in 2018, Luminate is a global philanthropic organisation with the goal of empowering people and institutions to work together to build just and fair societies, delivering impact in four connected areas that underpin strong societies: Civic Empowerment, Data & Digital Rights, Financial Transparency, and Independent Media. Since mid-2013 the Omidyar Network and since 2019 Luminate (an offshoot of the Omidyar Network), have been supporting Privacy International in building organisational capacity to become more resilient and strong leader within civil society. The grant received in 2024 from Luminate's new initiative Central Fund aims to support exploring themes of militarisation of tech through a project managed by PI until 2026.
## **Paul Hamlyn Foundation**
Paul Hamlyn Foundation's mission is to help people overcome disadvantage and lack of opportunity, so that they can realise their potential and enjoy fulfilling and creative lives. In February 2021 Pl received a 3-year grant to look into invasive data exploitation practices in immigration processes
32
**Privacy International**
**Notes to financial statements**
## **For the year ended 31 January 2025**
## **The Swedish International Development Cooperation Agency/SIDA**
The Swedish International Development Agency is supporting Pl in our collaboration with civil society actors in countries across east Africa, south and south-east Asia and South America. The 4-year project, which started in January 2017 and completed in April 2021, aimed to strengthen civil society's capacity to protect the right to privacy, while confronting datadriven transformations in power. In June 2021 PI received from SIDA grant to support PI's strategy through to January 2025.
## **GNP+**
GNP+ is a network for people living with HIV, run by people living with HIV. They engage with and support national and regional networks of people living with HIV this ensures that our global work is grounded in their local experiences and priorities. PI received funding from GNP+ to account for PI's role in the delivery of the project hosted at the University of Warwick’s Centre for Interdisciplinary Methodologies (CIM), until mid-2026.
## **Purposes of designated funds**
## **Activity fund 2024**
The 2024 activity fund represents funds set aside by the trustees in the 2021/22 and 2022/2023 financial years for delivery of strategic objectives, projects and activities in first year of new strategic year. The Trustees continue to monitor the use of the fund and was fully utilised by January 2025.
## **Strategic Fund 2026**
Strategic Fund 2026 represents funds set aside by trustees from unrestricted funding paid to PI in advance to support delivery of Strategic Plan 2023-2026. Trustees expect the fund to be utilised by 2026.
## **Fixed Asset fund**
The fixed asset fund represents the net book value of fixed assets at year-end as these are not freely available for the charity's use.
## **15 Operating lease commitments payable as a lessee**
The charity's total future minimum lease payments under non-cancellable operating leases is as follows for each of the following periods:
|Less than one year
One to five years|**2025**
2024
**£**
£
**96,075**
96,075
**72,056**
168,131
Property|**2025**
2024
**£**
£
**96,075**
96,075
**72,056**
168,131
Property|
|---|---|---|
||**168,131**|264,206|
## **16 Legal status of the charity**
The charity is a company limited by guarantee and has no share capital. The guarantors liability in the event the company is wound up is restricted to a maximum of £1 each.
33