Funeral Plans – Privacy Notice
Introduction
Central Co-op Funeral Plans (a trading name of Central England Co-operative Limited Funeral Plans Limited (CEC FPL)) is committed to ensuring the privacy of colleagues is protected. Should we ask you to provide personal data, then it will only be used in accordance with this Privacy Notice. CEC FPL collects and processes personal data relating to you to manage our employment relationship. We are committed to being transparent about how we collect and use that personal data and to meet our data protection obligations.
Who we are
Central England Co-operative Limited Funeral Plans Limited
ICO registration: ZB290665
Queen Street
Lichfield
Staffordshire
WS13 6QD
We have appointed a Data Protection Officer (DPO), who can be contacted via the following email address should you have any questions about the way your personal data is handled.
Email: enquiries@centralcoop.co.uk
Personal data we collect
Category of personal information | Description |
Identity details | First name, middle name(s), surname, membership number, information relating to your nominated representative. |
Contact details | Telephone number(s), email address(es), postal address(es), work address(es). |
Communication details | Feedback, questions, notes, any data that is contained within a message body or a subject from an individual. |
Funeral Plan details | Next of Kin, relationship to next of kin, funeral plan reference, funeral plan payments, any other personal data provided to allow us to make arrangements. |
Bank details | Sort code, card number, expiry date, account number, account name, bank branch, transaction date, payment information, total monies paid. |
Health data | Medical history, mental health details, disability details, all data concerning an individual’s health. |
How we collect your personal data
We will collect your personal data directly from you in the following ways:
- When you visit our website;
- When you consent to cookies on our website;
- When you correspond with us via email, text, telephone, social media or post.
- When you purchase a funeral plan from us;
- When you engage with us for a at need funeral service;
- When you make a card payment in one of our Funeral Homes;
- When you are captured on our CCTV systems;
- When you sign up to our Guest Wi-Fi;
- When you enter any competitions or prize draws with us; and
- When you consent to receive marketing from us.
We may also monitor or record telephone calls to:
- help us monitor the service our colleagues provide
- investigate and resolve complaints
- identify training needs
- ensure we can monitor and adhere to regulatory and quality standards
Calls recorded will normally be held for 42 months. We may also use recorded calls for analytical purposes to understand the call’s nature.
When we’re informed of something that could make you vulnerable in some way, we may securely record it for future reference if that’s the right thing to do. This is only the case when we are clearly told about a vulnerability. We do this so we can carefully plan how to ensure someone is not disadvantaged in any way.
Why do we process your personal data?
We are only allowed to process your personal data if we have a lawful basis to do so and are required to inform you of what that lawful basis is. We have set out in the table below: the purposes for processing your data, the categories of personal data affected, and the lawful basis on which we rely on when we process your personal data.
In some circumstances we can use your personal data if it is in our legitimate interest to do so, provided that we have told you what that legitimate interest is. A legitimate interest is when we have a business or commercial reason to use your information which, when balanced against your rights, is justifiable. If we are relying on legitimate interests, we have set that out in the table below.
Purposes for processing | Categories of personal data | Lawful basis for processing | Legitimate Interests (if applicable) |
To process card payments that you make at a funeral home. |
|
| N/A |
To process and deliver a funeral plan to you as a member or customer, including the management of payments and collect money owed to us. |
|
| N/A |
For the storage of your funeral plan with us in a dedicated Funeral Management System. |
|
| To use a bespoke system to efficiently store your data. |
To complete statutory paperwork relating to the funeral services we provide. |
|
| N/A |
To send you offers, vouchers and information about products and services. |
|
| N/A |
To administer any prize draws or competitions that you have entered. |
|
| N/A |
To communicate with your enquires, complaints and compliments. |
|
| To manage your relationship with us and further improve our services. |
To record health and safety incidents that in our funeral homes. |
|
| N/A |
To capture your image on our CCTV systems including body worn cameras, facial recognition and number plate registration. |
|
| For your safety and for the prevention and detection of crime. |
To confirm your identity when you visit one of our funeral homes. |
|
| To keep a record of attendees visiting loved ones. |
To conduct surveys and provide you an opportunity to give us feedback. |
|
| To gather feedback from customers and support the improvement of our services. |
To deploy non-essential cookies ono your device when you visit our website. |
|
| N/A |
To use anonymous data analytics to improve our website, products, services, marketing and experiences. |
|
| To continue to improve our services. |
Disclosures Of Your Personal Data
If you have a nominated representative we will share information about your funeral plan with them, such as the existence of the plan, its features and how to make a claim in the event of your death.
Sometimes we share your personal data with organisations we trust to process it on our behalf. They may only use this data for the purpose we agree with them unless they are required by law to process your personal data for other purposes. For example, Central Co-op assist with the sale of funeral plans and the sales administration
We may also need to share your personal information with other organisations or individuals:
Identity and credit reference agencies: To help us fulfil our anti-fraud and money laundering obligations.
Regulators: We may need to share your information with the Financial Conduct Authority for example, to evidence our compliance or assist them in any investigations from any complaints made about us.
Insurance Companies: When we receive the full payment for your Funeral plan, we will take out an insurance policy in your name. This ensures we are able to provide the benefits of the funeral plan in the event of your death, e.g. Royal London Mutual Insurance Society Limited (Royal London Policy).
Our professional advisors: We may need to share information with our auditors, legal advisors and other professional advisors when they need it to give us their professional advice.
Public authorities, agencies and government bodies: We may be required to share your information with bodies such as the police, courts, DVLA or HMRC.
Banks and financial institutions: When you pay by direct debit, we’ll share your payment details with the relevant banks.
Card payment services: When you pay by credit/debit card, we pass your payment and card details securely to our card payment service provider. We do not keep your card details.
Debt recovery companies: If any overdue amount is not paid, we may share your personal information with a debt recovery agent.
If requested, we will share your personal data with authorities such as:
- The Police;
- The Financial Conduct Authority;
- The Health and Safety Executive;
- Local Authorities;
- Her Majesty’s Revenue and Customs (HMRC);
- The Courts; and
- Central or Local Government Bodies.
Before we share your personal data with a third party, we will ensure that there is an appropriate Data Processing or Data Sharing Agreement in place to protect the sharing of data.
International Transfers
The EEA is the European Economic Area, which consists of the EU Members States, Iceland, Liechtenstein and Norway. If we transfer your personal data outside of the EEA, we must tell you and we must rely on one of the following:
- Adequacy Decision: The country we send your personal data to provides an adequate level of protection which has been approved by the European Commission.
- Standard Contractual Clauses (with the IDTA Addendum): The recipient of your personal data has provided us with signed Standard Contractual Clauses with the IDTA Addendum include. This holds the recipient accountable to safeguard the personal data.
- International Data Transfer Agreement (IDTA): The recipient of your personal data has provided us with a signed IDTA which has been approved by the Information Commission. This holds the recipient accountable to safeguard the personal data.
Instances where your personal data is transferred outside of the EEA are as follows:
Purpose of Processing | Personal data processed | Third Party | Location of data processing | International Safeguard |
Administration of the Funeral Management System |
| Firehawk Funerals Ltd | Australia | International Data Transfer Agreement (IDTA) |
How do we protect your personal data?
We take the security of your personal data seriously. We have internal policies and controls in place to ensure that we have implemented measures to ensure that your data is not lost, accidentally destroyed, misused, or disclosed without our authority, and is not accessed except by our colleagues only in the performance of their professional duties.
Where we engage third parties to process personal data on our behalf, they do so on the basis of written instructions, are operating under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
Retention of your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes of our processing. This includes satisfying any legal, accounting, or reporting requirements.
When we assess the retention of your personal data, we will take the following into consideration:
- Nature of the information;
- Sensitivity of the information;
- Potential risks if the information was breached;
- The purpose(s) for which we initially processed the information;
- Whether we can achieve the purpose(s) through less invasive means; and
- Any applicable legal requirements.
Your Rights
All individuals who engage with us have data subject rights relating to the processing of their personal data. These are the rights that apply to your personal data held within CEC:
- The right to be informed – you have the right to know what information we hold and process about you which is why we have provided this Privacy Notice.
- The right of access – you have the right to ask for a copy of the information we hold regarding yourself.
- The right to rectification – you have the right to ask for us to correct any information we hold which may be inaccurate or incorrect.
- The right of erasure – you have the right to have your personal data ‘erased’ in the following situations:
- Where the personal data is no longer required for the purpose(s) for which it was originally collected or processed;
- Where the processing was based on consent and you have withdrawn your consent;
- When the personal data was unlawfully processed; and
- When the personal data has to be erased in order to comply with a legal obligation.
We will erase your records when one of the above situations apply.
- The right to object – you have the right to object to the processing of your personal data in the following circumstances:
- The purpose of the processing activity is direct marketing;
- Where the processing is based on legitimate interests; and
- Processing for the purposes of scientific/historical research and statistics.
- The right to restriction of processing – you have the right to ask us to restrict the processing of your personal data in certain situations such as:
- Where you contest the accuracy of your personal data, we will restrict the processing until you have verified the accuracy of your personal data;
- When processing is unlawful, and you oppose erasure and request restriction instead; and
- Where we no longer need the personal data, but you require the information to establish, exercise or defend a legal claim.
- The right to data portability – You have the right to request that we transfer your personal data to a third-party. This right only applies to automated personal data which you have either provided your consent for us to use or where we have used your personal data to perform a contract with you.
- Rights in relation to automated decision-making including profiling – you have the right to question decisions being made about you without any human involvement.
If you would like to exercise any of these rights, please contact us at enquiries@centralcoop.co.uk
Changes to this Privacy Notice
We may update this Privacy Notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
If you have any questions in relation to this notice, please contact our DPO at enquiries@centralcoop.co.uk
Not happy?
Please let us know if you are unhappy with how we have used your personal data by contacting our DPO.
As stated in The Data (Use & Access) Act 2025, you have the right to lodge a data protection complaint with us, should you be unhappy with the way we have processed your personal data.
Your complaint will be managed and responded to by our Data Protection Officer (DPO). Their role will be a conduct an independent investigation into the grounds for your complaint and provide an outcome to you. Your complaint will be responded to with a final written response within 30 days of receipt.
Should you wish to make a data protection complaint, this can be done by contacting the DPO in the following ways:
Email: enquiries@centralcoop.co.uk
If you are dissatisfied with how your data protection complaint has been managed, you also have the right to lodge a complaint with The Information Commission (ICO). We would be grateful for the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
You can find their contact details below:
Address: Information Commission,
Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF
Telephone: 0303 123 1113