This is Bereavement Care’s privacy notice. Bereavement Care is a trading name of Southern Co-operative Funerals Limited. We respect your privacy and are committed to protecting your personal data. This privacy notice tells you how we look after your personal data; when you visit our website (regardless of where you visit it from) or when we collect it from you. It also tells you about your privacy rights generally in relation to the information we hold about you as a client or otherwise and how the law protects you.
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Bereavement Care collects and processes your personal data.
Our website is not intended for children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
When you use our website, social media pages or provide personal information to us by other means, you consent to us collecting and using the information in the ways set out in this policy.
CONTROLLER
Southern Co-operative Funerals Limited is the data controller in most cases, for example, in respect of data collected through your use of this website and where you use our bereavement services, such as counselling.
Bereavement Care is a trading division of Southern Co-operative Funerals Limited which is a member of The Southern Co-operative Limited (Southern Co-op) group of companies. Data is shared with other group companies where necessary for auditing purposes or where administrative services are provided internally within the group. The identity of these companies is set out in the Glossary at paragraph 10.
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, our use of your data or anything relating to the data we hold about you, please contact the DPO using the details set out below.
CONTACT DETAILS
Our full details are:
Full name of legal entity: Southern Co-operative Funerals Limited (Registered number: 382640)
DPO: [email protected]
Postal address: 1000 Lakeside, Western Road, Portsmouth, P06 3FE
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 28 July 2021. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of other websites.
Personal data, or personal information, means any information about an individual from which that person can be identified, or is identifiable. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your website Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
As a result of the specific counselling services we provide, we may collect Special Categories of Personal Data about you but only in most cases if we have your explicit consent. This may include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health. We do not collect any information about criminal convictions and offences. Aspects of this data may also be held for our colleagues, details of which are covered in our Colleague Privacy Notice.
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of the main ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground or basis depending on the specific purpose for which we are using your data. Please contact [email protected] if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To process and deliver an educational session to you as a client or a professional or counselling service to you as a client or invite you to a special event organised by Bereavement Care for our clients or notify you of other support services available | Identity
Contact
Profile
Bespoke
Special Category Data |
Performance of a contract with you
Performance of a contact with you and necessary for our legitimate interest (to provide a professional and sensitive service in line with good industry practice)
Consent |
| To manage our relationship with you which will include:
|
Identity
Contact
Profile
Marketing and Communications |
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated and to study how clients use our products/services) |
| To enable you to complete a survey | Identity
Contact Profile
Usage
Marketing and Communications |
Performance of a contract with you
Necessary for our legitimate interests (to study how clients use our services, to develop them and grow our business) |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity
Contact
Technical |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation |
| To deliver relevant website content | Identity
Contact
Profile
Usage
Technical |
Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business) |
| To use data analytics to improve our website services, client relationships and experiences |
Usage Technical |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business) |
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact [email protected].
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with third parties for the purposes set out in the table in paragraph 4 above. These may be Internal Third Parties, such as other companies within our group of companies as or External Third Parties such as service providers with expertise not available in-house as set out in the Glossary at paragraph 10.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer your personal data outside the European Economic Area (EEA), however, systems held to hold personal data may be accessed by system providers, or be hosted, outside of the European Economic Area. Where this is the case we require our system providers and host to secure your personal data in a manner consistent with the requirements of UK law.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We have higher levels of security in relation to Special Category Data in recognition of the sensitive nature of this information.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or other reporting requirements. Southern Co-operative Funerals Limited, a registered company under the Companies Act 2006. Registered number 382640. Registered office 1000 Lakeside Western Road Portsmouth Hampshire PO6 3FE.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting our Data Protection Officer on [email protected]
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data as set out below:
If you wish to exercise any of the rights set out above, please contact Bereavement Care or the Data Protection Officer by emailing: [email protected].
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting [email protected]
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means processing your personal data where we have your specific consent to do so. You have a legal right to remove or amend this consent by contacting [email protected]
INTERNAL THIRD PARTIES
Southern Co-operative Funerals is a member of The Southern Co-operative Limited (Southern Co-op) group of companies.
Other companies in the Southern Co-op group acting as controllers or processors and who are based in the UK and who provide products and services:
| Company | Products/services |
| The Southern Co-operative Limited | Food and retail convenience stores |
| Mutual Services (Portsmouth) Limited | Funeral services |
EXTERNAL THIRD PARTIES
These are third parties outside the Southern Co-op group which provide services where we do not have the expertise or resources to provide them in house or to whom we are required to pass on your data in order to fulfil the relationship we have with you or for other legal reasons. Examples of these entities are set out below: