Adur & Worthing Bereavement Services Privacy Notice

What this Privacy Notice covers

Adur & Worthing Councils are the data controllers (referred to in this notice as 'we' or 'us') of your personal data for the purposes of applicable data protection legislation in relation to the administration and management of the following:

The Councils' Data Protection Officer can be contacted at:

In relation to your personal data we are committed to collecting, using and protecting it appropriately. To view our Data Protection Policy see:

This privacy notice explains:

  • How and why we collect and use your personal data  
  • The type of personal data that we collect  
  • When and why we may share personal data with other organisations  
  • The rights and choices you have in relation to the personal data that we hold about you  
  • How long the information is kept for  
  • Our legal basis for processing your data   

What we collect, why and how it is used 

We collect the following personal information:

  • The purpose of collecting and processing your personal data is to administer the arranging of a cremation or a burial. 

Cremation

  • Your name and address (the applicant) are recorded in the Cremation Register. As set out in The Cremation Regulations 2008 (Part 7)(Regulation 33).
  • The Cremation Register is not a public document, but the cremation authority may issue to any person a copy of, or an extract from, the register or a document.
  • Your name, address, contact details are collected and held and used for the purpose of administering the arranging of a cremation.

Burial

  • The following as set out in The Local Authorities Cemetery Order 1977, namely the applicant’s name and address are recorded in:
    • The register of burials under articles 11 (1)
    • The record of disinterments maintained under article 11 (5)
    • The register relating to the provision as to grants, extensions of the periods thereof and matters concerning rights under Part II of schedule 3
  • The records of memorials made and kept under paragraph 16 of Schedule 3
  • Registers of burials and records of disinterments are available at all reasonable times available for inspection by any person free of charge.
  • The burial authority may charge a fee for making searches in, and the provision of certified copies of entries in, a register of burials or a record of disinterments.
  • Your name, address, contact details are collected and held and used for the purpose of administering the arranging a burial, provision of grants, extensions of the periods and matters concerning rights.
  • Your personal data may be converted ('anonymised') into statistical or aggregated data in such a way as to ensure that you are not identified or identified from it. Aggregated data can't by definition, be linked back to you as an individual.
  • This data might be used to conduct research and analysis, including preparing statistical research and reports.

The type of personal data that we collect  

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: 

  • Identity Data includes first name, last name, title, date of birth and gender and your image. 
  • Contact Data includes postal address, email address and telephone numbers. 
  • Financial Data includes bank account and payment card details. 
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us 
  • Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. 
  • Profile Data includes purchases or orders made by you, your preferences, feedback and survey responses. 
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. 
  • Bespoke Data includes in individual cases specific data such as health information provided in relation to a specific enquiry or arrangement.

We may collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your mental health and genetic and biometric data) because you provide this information to us as a result of us arranging cremation services. We also collect biometric data in our use of CCTV systems at Worthing Crematorium. We do not collect any information about criminal convictions and offences. 

When and why we may share personal data with other organisations

We may collect and process personal data from a third party such as a funeral director, celebrant, ministers, monumental masons, specialist funeral service providers etc.  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 may receive personal data about you from various third parties and public sources such as independent funeral directors who are arranging for us to provide services to you on their behalf, or from review sites such as Google, Facebook etc. when you carry out a review of our business or services. We may need to share personal data for law enforcement, regulation and licensing, criminal prosecutions and court proceedings. We may need to share personal data in order to establish, exercise or defend our legal rights (this includes personal data to others for the purposes of the prevention and detection of fraud).

Data sharing with external third parties

These are third parties outside the Councils’ 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. 

  • Service providers acting as processors who provide IT and system administration services, CCTV services, digital, videoing, broadcast, streaming and photographic service providers, email deployment providers.
    See: Attending a webcast via Obitus
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services. 
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances. 
  • Service providers such as market researchers, advertising agencies, local authorities, debt collection services providers, mailing house fulfilment, funeral service providers (for example, funeral directors, memorial products and services providers, officiants, specialist funeral service providers etc.), etc. 

We will not provide personal data to anyone else or use the data about you for any other purpose unless the law allows or permits us to. 

Your personal data may be converted ('anonymised') into statistical or aggregated data in such a way that ensures that you cannot be identified from it. Aggregated data can't, by definition, be linked back to you as an individual and may be used to conduct research and analysis, including the preparation of statistics for use in reports.

Data security

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 colleagues, 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. 

The rights and choices you have in relation to the personal data that we hold about you  

Your rights:

You have certain rights under the UK Data Protection law including:

  • The right to be informed
  • The right of access to your personal data (also known as a Subject Access Request or SAR)
  • The right to withdraw consent 
  • The right of rectification (to have any inaccuracies corrected)
  • The right of erasure (to have your records deleted)
  • The right to restrict processing
  • The right to data portability
  • The right to object
  • Rights in relation to automated decision making and profiling

Further information about your rights is available on the:

If you have a concern about the way that we are collecting or using your personal data, we ask that you contact us in the first instance. Alternatively, you can contact the Information Commissioner's Office.

How to contact us

If you have any questions about how we collect, store, or use personal data please email us as listed below:

How long the information is kept for

Cremation

  • A cremation authority must keep the application for cremation and any other certificates or documents relating to a cremation, or an electronic copy of the documents, for a period of 15 years from the date of cremation. Where electronic copies of application forms and documents are kept, the originals must be kept for two years.
  • The Register of Cremations is kept in perpetuity.

Burial

  • The burial authority must keep all records and registers in perpetuity, stored so as to preserve them from loss or damage
  • Records are kept in accordance with the Council's Information Retention and Disposal Schedule  and we will not keep your information for longer than necessary.

Our legal basis for processing your personal data

The legal basis for processing your personal data is:

  • We are relying on UK GDPR Article 6(1)(b) as the lawful basis for processing. Processing is necessary for the performance of a contract to which the data subject is party, or for the taking steps at the request of the data subject prior to entering into a contract. (To process and deliver an order or service to you as a client including:
    • (a) Provide cremation and funeral services to you, manage payments, fees and charges
    • (b) Collect and recover money owed to us
    • (c) Inform you about memorial products and services and assistance
    • (d) Inform you about other services we offer such as bereavement support and memorial events).
  • We are relying on UK GDPR Article 6(1)(c) as the lawful basis for processing. Processing is necessary for compliance with a legal obligation which means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to, namely the Cremation Regulations 2008 for England and Wales and The Local Authorities Cemeteries Order 1977. 
  • We are relying on UK GDPR Article 6(1)(f) as the lawful basis for processing. Processing is necessary for our legitimate interests pursued by the controller or a third party except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child; (to protect our business against criminal activity and to protect the safety of our colleagues, members and customers) 

Last reviewed: 23/03/2022

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