Scotmid Funerals, Thomas Brown Funerals and Dundas Fyfe Funerals are part of Scottish Midland Co-operative Society Ltd
which is an Industrial and Provident Society with company number SP2059RS and with its principal office at Hillwood House,
2 Harvest Drive, Newbridge, EH28 8QJ. We strive to protect the privacy of all personally identifiable information collected
during the course or our activities and it is important for you to know how we process your data. We will process your
personal information under the terms of this notice and in accordance with any agreement with you.
We are a “data controller” in terms under data protection laws (including from 25 May 2018, the EU General Data Protection
Regulation 2016 and the Data Protection Act 2018) (“Data Protection Laws”).
We need to process personal data relating to our suppliers and customers in order to function effectively as a business,
ensure good governance, for audit purposes, to perform our business and to enable us to meet our legal obligations.
Personal data is processed for commercial, administrative and statutory purposes. All such personal data is collected and held
in accordance with all applicable Data Protection Laws.
What data do we hold and what do we use it for?
When we arrange a funeral or a funeral plan we obtain contact details from the person taking responsibility for the funeral costs (our “Client”) when arranging the funeral or a funeral plan so that we can liaise with them during the process and have an address, telephone number and sometimes an email address. Our Client is therefore either the person who arranges their own funeral plan; or a person that takes responsibility for arranging a deceased person’s funeral.
Funeral plan and funeral arrangements are held on a central database which lists a Client’s preferences and enable us to access our Client’s request in relation to funeral arrangements.
In order to organise funerals we maintain a list of contact details for members of the clergy, humanist celebrants, organists, pipers and other specialist providers. This information is retained in a database in our funeral system. We also use this information in our purchase ledger to make payments and in order to do this we may obtain and hold bank details for these providers.
Special category data is considered to be particularly sensitive and religion is included in this classification. Where a religious ceremony is listed, this is classed as special category data. We hold this information securely within our database.
The legal basis for holding this data
The legal basis we rely on for processing data about our Client in relation to the funeral or funeral plan arrangements is on the basis of the contract we have with our Client. In relation to the other personal data that we process, this is likely to be on the basis of our legitimate interests in administering our business and performing our services. We may also require to process personal data in the course of ensuring that we comply with any legal obligations relating to funerals.
Where we process details of our Client’s or any other person’s religion, this is either on the basis of explicit consent or it is on the basis that the data has been manifestly made public by the Client or relevant person.
We also seek direct feedback from our Client following a funeral and this is why we issue questionnaires to all Clients or their next of kin or other person that took responsibility for the funeral arrangements. This helps us to ensure that we provided a high quality service and to ensure that we will continue to improve on the services we provide. We also ask our Client or their next of kin or other person that took
responsibility for the funeral arrangements whether they would like to receive information on memorials and selected aftercare services. It is in our legitimate interests to do so and, if the relevant person agrees to receive such information then from then on we will process their data on the basis of their consent.
We may also use the data to perform some data analytics to identify patterns that give insight to our business. Again this is on the basis that it is in our legitimate interest to help us improve our business and our services. This is an internal process and, in so far as possible, we may anonymise this information where Client name is not important.
Where do we obtain your information?
In most cases we will obtain this information from you directly.
Processing conditions
We process the personal data referred to above for the purposes of any contract or potential contract with our suppliers and customers; or for our legitimate interests in order to function effectively as a business, to ensure good governance, for audit purposes, to perform our business
activities; and to enable us to meet any legal obligations that we may be subject to. We also process some data on the basis of consent. With regard to data about religion, we process this data on the basis of explicit consent or on the basis that the data has been manifestly made public by the Client or relevant person.
Who do we share your information with?
The information you provide to us may be accessed by our staff, auditors, insurers, insurance brokers, solicitors, professional advisors and carefully selected third parties in the course of providing services to us under suitable obligations of confidentiality. In some cases we may also share data with credit reference agencies, debt collection and tracing agencies. As described above, we may share information
with members of the clergy, humanist celebrants, organists, pipers, crematoria, cemeteries and other specialist providers for the purposes of performing our services and arranging funerals. We may also be required to provide information on request or where required tothe Procurator Fiscal, Police Scotland, HM Inspector (of Burial, Cremation & Funeral Directors), Competition & Markets Authority (CMA), Scottish Government, Financial Conduct Authority (FCA), Social Services and other relevant statutory authorities.
Scottish Midland Co-operative Society Limited is an appointed representative of Ecclesiastical Planning Services Limited. In order for us to provide funeral plans, we share data with them and provide a buy online facility through our website which links to their website.
What information do we share?
Some of our service providers may have access to your data in the course of providing software or IT support. Their access is strictly controlled and they are subject to appropriate confidentiality obligations.
In order to complete arrangements for a funeral we may need to pass on your contact details to specific funeral service providers who may need to contact you to clarify details. We will also help you complete cremation or burial forms which then require to be passed on the selected location.
We share funeral plan holder names and amounts with the insurer who underwrites the plan. This information is securely transmitted.
We will help Clients with repatriation if necessary and so will have to share details with funeral directors outwith the UK on occasion. We will discuss any information that we require to share in advance on a case by case basis. Usually the initial contact is made directly by the Client to the overseas funeral director and then we liaise regarding the details of handling the deceased’s transfer.
Online obituary services are now on offer from different service providers. As part of our arrangements we offer families the opportunity to use “Much Loved” to place a funeral notice. If a Client accepts this, we pass on details of the deceased and then the Client will create their own account with Much Loved and post any additional details. Our Client then becomes a direct Client of Much Loved and data shared with Much Loved is subject to their privacy policy, which can be viewed via this link: www.muchloved.com/gateway/privacy-policy.
How long do we keep your data?
We will retain personal data securely and only in line with how long it is necessary to keep for the purposes or for a legitimate and lawful reason.
Some personal data may be retained for longer where it is in our legitimate interest to do so, such as to protect and defend our legal rights; or for research, archiving or statistical purposes. In particular we retain some basic information about funerals indefinitely for archiving purposes and to protect and defend our legal rights. This information is limited to name, current address and telephone number and funeral
preferences. This information is retained on our funeral system and arrangement forms and copies of cremation or burial documents are retained. Individuals can request that other information relating to them be erased and we will deal with such requests in accordance with the law.
CCTV
We operate CCTV in some of our offices. This is done on the basis of our legitimate interests in relation to health and safety, security and crime prevention; and to establish, protect and defend legal claims. The images will be processed in accordance with applicable data protection legislation.
Complaints
If you have a complaint regarding our use of your data or the way we have handled any request from you to exercise any of the rights requested above then we ask that you contact our Data Privacy Manager, dataprivacymanager@scotmid.co.uk or by telephone on 0131 335 4400 in the first instance so we can take remedial action, however you also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues at www.ico.org.uk or call 0303 123 1113.
Data security
We have put in place appropriate technical and organisational security measure to protect the security and confidentiality of your personal data. In addition we have procedures to deal with any data security breach and will notify any affected data subjects and/or the Information Commissioner in compliance with the law if a breach occurs.
The use of cookies
In common with many other website operators, we do employ cookies (download of files to your device to record your visits to the site) to measure site information. Most browsers automatically accept cookies, but you can usually change your browser to prevent cookies being stored. Please note, if you do turn cookies off this will limit the service that we are able to provide to you and may affect your visitor experience. For further information on cookies and how to switch them off see www.allaboutcookies.org
Your data rights and obligations
Please inform us of any changes to your contact details. Details of your data rights and obligations are below. If you have a concern regarding the accuracy of your personal data held by Scotmid Funeral Directors, please contact the us to request an amendment to the data on Info@scotmidfunerals.coop, 0800 996 1927.
If you wish to exercise any of your rights or have any other questions regarding our use of your data, please contact our Data Privacy Manager.
Under certain circumstances, you have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If any person wishes to make a request on any of the above grounds you may contact our Data Privacy Manager, on the contact details below. Please note that depending on the nature of the request, we may have good grounds for refusing to comply. If that is the case, we will provide an explanation to you. Generally no fee will be payable, however, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive (particularly if it is repetitive). We may also charge a reasonable fee to comply with further copies of the same information. Alternatively, we may refuse to comply with your request in these circumstances.
Changes to this Privacy & Fair Processing Notice
We keep our Privacy & Fair Processing Notice under regular review and reserve the right to update and amend it. This notice was last updated in October 2022. Scottish Midland Co-operative Society Limited trading as Scotmid Funerals, Thomas Brown Funerals and Dundas Fyfe Funerals – ICO registration number Z5336218.