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Privacy policy

The terms “we”, “us”, “our” and “ours” when used in this Privacy Policy means Ecclesiastical Planning Services Limited (and subject to change from time to time). The terms “you”, “your” and “yours” when used in this Privacy Policy mean any user of our website, enquirer or customer.

Your privacy is important to us. We (as the data controller) will always act responsibly with your data. We are committed to the privacy and confidentiality of information provided by you to us. This Privacy Policy describes our current policies and practices with regard to Personal Data collected by us from you directly and/or through the website where such Personal Data is protected by the General Data Protection Regulation (“GDPR”).

The term “Personal Data” refers to personally identifiable information such as name, address, date of birth and telephone number. The term “Special Category Data” refers to more sensitive data such as information regarding religion, race, ethnic origin, genetics, politics, trade union membership, health, etc. We will process personal data, which may include Special Category Data, in accordance with the applicable data protection law and on the legal basis that is necessary to set-up, administer and carry out the funeral plan, and for business management purposes.

We will also share your data with the whole of life assurance policy provider to which your plan is linked and your selected funeral director in order that they can carry out the plan.

We will share your data with an alternative funeral director of your choosing if you move to a different area.

In addition, if you purchase a funeral plan from one of our carefully selected affinity partners, the partner firm will hold and process your data also. We do not share, sell nor distribute Personal Data to unrelated third parties for marketing purposes.

Collection and use of Personal Data including e-mail addresses

You may provide us with your Personal Data in order to receive information, advice, products or services from us. We may request personal information about you such as your name, address, date of birth, email address, telephone number and we may ask for information which enables us to provide a personalised service to you. We may also capture the following information if it is provided it as part of the funeral plan application:

- The plan purchaser’s title, first name, surname, address, postcode, telephone number and date of birth.
- The next of kin, executor or personal representative’s details.
- Any information relating to funeral arrangements as part of the funeral plan application, which may include Special Category Data such as religion or lifestyle information, for example, as part of the funeral arrangements and/or in a eulogy that is held as part of the funeral plan, to be shared at the funeral.
- Information relating to the method of payment used to pay for the funeral plan.

If you request information from us, we will store your Personal Data for period of three months and it will then be securely destroyed, unless you ask us to contact you in the future or take out a plan in which case we will store your data in line with this privacy policy. We hold customer data received in telephone calls via our telephony system for 12 months for training and monitoring purposes.

We sometimes supplement the information that you provide with information that is received from third parties. For instance, if inaccurate postcodes are received, we will use third party software to fix them.

To comply with money laundering regulations, for funeral plans with a value of £15,000 or more, we may need to request additional evidence of identity from you, and may use a credit reference agency for this purpose (who will record that an enquiry has been made). We will let you know which agency we will use at the time of the request. We also reserve the right to monitor and/or record your communication with us by mail, voice, email or any other form of transmission for the purposes of quality control, security and other business needs. Any Personal Data which may include Special Category Data contained in such recorded information will be processed in accordance with the terms of this Privacy Policy.

We may also receive your Personal Data from other members of the Ecclesiastical Group (as listed in the footer below), our service providers, agents or advisers including external independent financial advisers (IFAs) or business partners (as shown on your funeral plan application form). Where Personal Data is disclosed to us by third parties, it is the obligation of the disclosing party to ensure such Personal Data is disclosed with requisite authority and consent and we will process such Personal Data in accordance with this Privacy Policy.

If we receive a funeral plan application form that includes the Personal Data of a third party for example, relating to a power of attorney, next of kin or planholder (where someone buys a funeral plan on behalf of someone else), we may process such Personal Data in order to provide the funeral plan. In addition, we may hold information about your position as attorney for the purpose of administering products or services to the third party for whom you act as attorney.

We process your Personal Data only for specific and limited purposes. We ask only for data that is adequate, relevant and not excessive for those purposes. Some of these purposes may include the following: 

- To provide your funeral plan 
- To process your funeral plan claim 
- For the purposes of accounting
- To keep our records up to date for example if you change address or ask us to transfer your plan to an alternative funeral director
- To process your request for information or advice
- To process your job application
- To identify deceased plan beneficiary’s for funeral plans in force i.e. where the funeral has been carried out but the plan has not been claimed. We use the ‘heir trace’ services of Accurate Data Services, Suite 2, The Old Dairy, Elm Farm  Norwich Common, Wymondham, Norfolk NR18 0SW to identify deceased plan beneficiaries and will look to refund funeral plan funds to the relevant estate.

When you sign your application form, you give us consent to process your data which may include Special Category Data. We hold Personal Data which may include Special Category Data for funeral plans that have been claimed upon for a period of seven years in case of queries, fraudulent claims and complaints. Information is then securely deleted. You can cancel your plan in writing or via email and we will update our records and process the cancellation in line with our terms and conditions. We will retain your records for a period seven years in case of queries, fraudulent cancellations and complaints. Records will then be securely deleted after this time.

Anonymous data collected through this website

In addition to the information we collect as described above, we use technology to collect anonymous information about the use of our website. For example, we use technology to track which pages of our website our visitors view. We also use technology to determine which Web browsers our visitors use. This technology does not identify you personally; it simply enables us to compile statistics about our visitors and their use of our website.
We use this anonymous data to improve the content and functionality of our website and our e-mail updates, to better understand our customers and visitors, and to improve the services we offer.

Cookies

In order to collect the anonymous data described in the preceding paragraph, we may use temporary “cookies” that remain in the cookies file of your browser until the browser is closed. We consider none of them to be intrusive to you; in fact some will enhance your experience on our website.  The cookies that we collect are:
Cookie Law Compliance - This cookie is placed if you click the Allow button in the cookie message. It tells us you have given your consent to the use of cookies on our site and stops this message from displaying.
Session and Person ID Cookies – These allow us to place you on a more suitable page based on your previous visits to our website – it will enable you to get to the content we believe you want, quicker. We collect no personal data that would enable us to physically identify you from this Cookie.
Website Analytics data – We’ll not collect data that enable us to identify you. The only cookies which you may consider could be intrusive are those that identify which county/area of the country you come from, and if you are a new, or returning visitor.
__utma, __utmb, __utmc and __utmz cookies - We use Google Analytics. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they’re using it. This helps us to improve the way our website works, for example by making sure users are finding what they need easily.
NID & PREF cookies – These cookies are third party cookies used by Google. Please take a look at the Google policy to see how they use these cookies. www.google.com/intl/en/policies/privacy/
Google re-marketing code – We may use a cookie to track you on other sites and show adverts to you based on where you have visited on our site. We do this to remind you of our services in case you wish to come back and buy them. We only use these cookies for 30 days after your last visit to our website. We do not control these cookies, so these will be unaffected by the choice you make today. You may opt out of the use of cookies by visiting Google advertising opt-out page.
Google AdSense – We use this cookie to report to us how the adverts shown on our websites are performing. User data is all anonymous.
You can find out more generally about Google and its policies and principles as regards advertising at http://www.google.com/policies/privacy/ads/
You Tube cookie – We use this cookie to help maintain the integrity of video statistics, prevent fraud and improve site and video experience. If you play any of the videos in our website, it will drop a cookie. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not.
We also use your IP address to help diagnose problems with our server and to administer our website. An IP address is a numeric code that identifies your computer on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information, such as determining how many of our visitors are from outside of the UK. We may also perform IP lookups to determine which domain you are coming from (i.e. aol.com, yourcompany.com) to more accurately gauge our users' demographics. If you choose to accept these cookies, we believe that it will only enhance your experience on our website. If you choose to accept these cookies, we can’t change that choice for you in the future. We may add further cookies which we consider to be no intrusive in the future. By agreeing to the cookies today, you are also agreeing to cookies which we may choose to use in the future.

Disclosure of your Personal Data

We do not share with, nor sell nor distribute your Personal Data to unrelated third parties for marketing purposes.

We may share various details about you with our partners, and other agents in order to provide you with the specific service you require or to look after products you have with us, or in connection with your funeral plan, and in the processing of funeral plan claims.
Personal Data may occasionally be transferred to third parties who act for us for further processing in accordance with the purposes for which the data was originally collected or for purposes to which you have consented or otherwise in accordance with this Privacy Policy. For example, sometimes a third party may have access to your Personal Data in order to support our information technology or to handle mailings on our behalf.

We may share or transfer the information in our databases to comply with a legal or regulatory requirement, for the administration of justice (for example law enforcement agencies), interacting with anti-fraud databases, to protect your vital interests, the Unclaimed Assets Register (for example in connection with the possible recovery by you of unclaimed distribution payments) to protect the security or integrity of our databases or this website, to take precautions against legal liability, or in the event of our sale, merger, reorganisation, transfer of business, dissolution or similar event.

If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

- Checking details on applications. 
- Managing credit and credit related accounts or facilities.
- Recovering debt.
- Checking details on proposals and claims.

We and other organisations may access and use information provided by fraud prevention agencies.

If we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets. Where appropriate, before disclosing Personal Data to a third party, we contractually require the third party to take adequate precautions to protect that data and to comply with applicable law.

Please contact the Data Protection Officer at the address below if you would like to receive details of the relevant fraud prevention agencies.

Data Integrity and Security

We strive to maintain the reliability, accuracy, completeness and currency of Personal Data in our databases and to protect the privacy and security of our databases. The security measures in place on our website and computer systems, aim to protect the loss, misuse or alteration of the information you provide to us. We keep your Personal Data only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or regulatory requirements, or our data retention policy.

We implement and maintain appropriate technical and organisational measures to ensure the ongoing confidentiality, integrity, availability and resilience of information processing systems and services. This includes, but is not limited to, conducting due diligence on our suppliers, testing effectiveness of information security, operating a framework of information security controls and documenting our policies which are regularly reviewed.

Subject Access Request

Upon receipt of your written request and enough information to permit us to identify your Personal Data, we will (subject to the exceptions to the requirement to disclose under GDPR) disclose to you the Personal Data we hold about you, for example if you wish to see a copy. We will respond to your request within one calendar month of receiving it. We may ask you to provide further information and/or validation of your identity.  We will store details of subject access requests indefinitely. If we receive multiple requests, we reserve the right to make a small charge.
If you wish to make a subject access request, relating to Personal Data held about you by the Ecclesiastical Group of companies, please write to The Data Protection Officer, Ecclesiastical Planning Services, Beaufort House, Brunswick Road, Gloucester GL1 1JZ or call us on 0800 633 5626.

Withdrawing your consent for us to hold data including Special Category Data

You can withdraw your consent for us to hold your data including Special Category Data but this may mean we are unable to carry out your funeral plan which will be cancelled in line with our Funeral Plan Terms and Conditions.

Right to be forgotten

You can ask us to remove or delete your Personal Data from our records if there is no compelling reason for us to hold it and subject to specific circumstances under the General Data Protection Regulation. Requests to delete Personal Data are subject to any applicable legal and regulatory requirements or document retention obligations and any of our current contracts which are still in force.

Right to data portability

Upon your written request, you can ask us to transfer your machine-readable Personal Data held in our systems to an alternative provider for example. The data would be restricted to your Personal Data, your funeral plan name and value. Alternatively we can provide information to you in order that you can pass it to third parties. We will respond within one calendar month of receiving your request.

Customer satisfaction surveys

From time to time we issue anonymous customer satisfaction surveys which you can choose to complete or ignore. The purpose of the survey is to find out why you took out a funeral plan and to ensure you received appropriate information during the process. Our surveys can be completed anonymously. We collate the results and use these for business decision making and for monitoring and quality control purposes. We may also share the overall results with funeral directing firms.
If you provide your Personal Data as part of this process and provide consent for us to share your views with your funeral director, we will do so but we will not share your Personal Data. This information will not be used for marketing purposes. We will anonymise surveys results within three months of the survey closing date.

Inaccurate Data

Please let us know if your Personal Data becomes out of date or incorrect by email, telephone or in writing and we will correct, amend or delete any Personal Data that you notify us is inaccurate and notify any third party recipients of the necessary changes. Our contact details can be found at the end of this privacy policy.

Links to other websites

Our website may contain hyperlinks to websites that are not operated by us. Any such hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of these third-party websites or any association with their operators. We do not control these websites and are not responsible for their data or privacy practices. We urge you to review any privacy policy posted on any site you visit before using the site or providing any Personal Data about yourself.
Our website contains hyperlinks to other pages on our website. We may use technology to track how often these links are used and which pages on our website our visitors choose to view. Again this technology does not identify you personally – it simply enables us to compile statistics about the use of these hyperlinks.

Transfer of Data Abroad

Ecclesiastical Planning Services does not transfer data outside of the EEA. If data processing takes place outside the European Economic Area, we will make suitable arrangements for your personal information to be protected.

Unsubscribe

We will not send you information about other products and services.

Complaints

Please refer to our complaints policy in your funeral plan terms and conditions. If you need more information on how we handle complaints, we can send you a copy of our complaints procedure. If we cannot resolve your complaint, you may refer it to the Funeral Planning Authority by calling 0845 601 9616.

If you are unhappy with the way in which your data has been handled, you can write to the Information Commissioner’s Office (ICO) if you believe we have breached data protection laws. For more information visit www.ico.org.uk. Making a complaint with the ICO will not affect any other legal rights.

Governing Law

This Privacy Policy forms part of our website Terms of Use and as such shall be governed by and construed in accordance with the laws of England. You agree to submit any dispute arising out of your use of this website to the exclusive jurisdiction of the courts of England.

Questions

If you have any questions about this Privacy Policy, or any part of our service, you may contact us by emailing info@epsfunerals.com or telephoning The Data Protection Officer on 0845 777 3322. Our address is: Ecclesiastical Planning Services, Beaufort House, Brunswick Road, Gloucester GL1 1JZ.

Changes to privacy policy

This privacy policy may change from time to time, and we will let you know when changes that materially affect you have been made.


Our group of companies includes Ecclesiastical Insurance Group plc (EIG) Reg No 1718196. Ecclesiastical Insurance Office plc (EIO) Reg No 24869. Ecclesiastical Life Ltd (ELL) Reg No 243111. Ecclesiastical Financial Advisory Services Ltd (EFAS) Reg No 2046087. Ecclesiastical Underwriting Management Ltd (EUML) Reg No 2368571. E.I.O. Trustees Ltd Reg No 941199. EdenTree Investment Management Ltd (EIM) Reg No 2519319. All companies are registered in England at Beaufort House, Brunswick Road, Gloucester GL1 1JZ. EIO and ELL are authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Firm Reference Number 113848 (EIO) and 110318 (ELL). EFAS and EIM are authorised and regulated by the Financial Conduct Authority. Firm Reference Number 126123 (EFAS) and 527473 (EIM). EUML is an appointed representative of EIO who is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Firm Reference Number 402228.

This privacy policy was last updated on 25 May 2018.

Ecclesiastical Planning Services Limited (EPSL) Reg. No. 2644860. EPSL is an Appointed Representative of Ecclesiastical Financial Advisory Services Limited (EFAS) Reg. No. 2046087. EFAS is authorised and regulated by the Financial Conduct Authority. Firm Reference Number 738805 (EPSL) and 126123 (EFAS). Both companies are registered in England at Beaufort House, Brunswick Road, Gloucester GL1 1JZ.
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