Pure Cremation Privacy Notice
Who we are
This notice applies to all entities within Pure Cremation Group Limited (‘we’ or ‘us’ or ‘our’) and includes;(Pure Cremation Limited (09703301), Pure Cremation Funeral Planning Limited (09906976), Pure Life Financial Services (13149243)).
We gather and process your personal information in accordance with this privacy notice and in compliance with the relevant data protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.
Pure Cremation Group Limited is based in Andover, England and registered with Companies House (10723077). We are registered on the Information Commissioner's Office Register; and act as the data controller when processing your data. Our Groups’ Data Protection Manager is Abech Deme, dpo@pure.uk.com.
Information we collect
We processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.
The personal data that we collect is: -
- Names, Date of Birth, Home Address
- Personal Email, Phone Number
- Employment status
- Marital Status
- Nominated Representative
- Details of your interaction with us through our contact centers via audio recordings
- Billing information including; signature, transaction, bank account/card details
- CCTV images at our Premises
- Special Category Data (vulnerability data)
We collect information in the below ways: -
- When you call to enquire about our services;
- Online forms
- Postal Forms
- Someone else acting on your behalf who gives us the information directly
- Employment Application process
- Survey Questionnaires
How we use your personal data
We take your privacy very seriously and we will never disclose, share, or sell your data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and/or marketing, you are free to withdraw this consent at any time.
The purposes and reasons for processing your personal data are detailed below: -
- We collect your personal data in the performance of our contractual obligation to provide a funeral related services and to ensure that the plans you have with us is properly managed
- We collect and store your personal data as part of our legal obligation for business accounting and tax purposes
- We record the details of your interaction with our call agents for training, quality assurance and monitoring purposes on the grounds of legitimate interest
- We collect and process your personal information when you make an enquiry on our website for an information pack for funeral plans in order to respond to your enquiry and contact you to establish your demands and needs and discuss your options
- We will occasionally send you marketing information where we have assessed that it is beneficial to you as a customer and in our interests. Such information will be non-intrusive and is processed on the grounds of legitimate interests
- We utilize CCTV to record images of individuals and their vehicles. This data is collected for the personal safety of employees and clients; protection of vehicles against damage or vandalism and to support law enforcement
Your rights
You have the right to access any personal information that we processes about you and to request information about: -
- What personal data we hold about you
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data for
- If we did not collect the data directly from you, information about the source
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
Sharing and disclosing your personal information
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. We outsource our mailing services to third parties.
- Send out information packs to individuals who have expressed an interest in our services and
- Send out funeral plan documents to individuals who purchase plans with us
- And payments made to your insurance backed plan, used to purchase a Whole of Life Policy with Scottish Friendly Assurance Society Limited, who are one of the largest mutual life offices in the UK
All processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.
Law enforcement
We utilise CCTV as part of our business and activities. The reasons for using CCTV are noted under the ‘How We Use Your Personal Data’ section above. We may disclose CCTV footage to law enforcement agencies where it is required in the detection or prosecution of crime. We retain a record of all CCTV footage disclosures.
Safeguarding measures
We take your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.
UK Processing and Transfers outside the UK
Personal data in the United Kingdom is protected by the UK GDPR but some other countries may not necessarily have the same high standard of protection for your personal data. We do not transfer or store any personal data outside the UK.
Consequences of not providing your data
You are not obligated to provide your personal information to us however, as this information is required for us to provide you with funeral plans, without your personal information we will not be able to provide you with our services.
Legitimate interests
As noted in the ‘How We Use Your Personal Data’ section of this notice, we occasionally process your personal information under the legitimate interests’ legal basis. Where this is the case, we have carried out a thorough Legitimate Interests’ Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
We use the legitimate interests’ legal basis for processing call recordings at our call center for quality, training and monitoring purposes to ensure our staff are performing and delivering high quality customer care services to our customers.
How long we keep your data
We only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.
Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.
Special category data
Owing to the services that we offer, we sometimes need to process sensitive personal information (known as special category data) about you, to comply with regulatory requirements. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.
Lodging a complaint
We only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however you wish to raise a complaint regarding the processing of your personal data, please contact our DPO;
Abech Deme,
Group Data Protection Manager
If you are not satisfied with how your complaint was addressed by us, you have the right to lodge a complaint with the Commissioner;
Information Commissioner’s Office
Wycliffe House, Water Lane, Wilmslow SK9 5AF
Telephone: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
Email: enquiries@ico.org.uk