Sections
Section 1 - Scope
In this privacy notice, ‘us’, ‘we’ or ‘our’ refers to Golden Charter Limited. Golden Charter Limited trading as Golden Charter Funeral Plans is authorised and regulated by the Financial Conduct Authority, FRN: 965279.
This notice applies to all data subjects (you) whose personal data is collected regardless of the method in which we collect the information (such as online, by telephone, letter or face to face), in line with the requirements of the UKGDPR and the Data Protection Act 2018.
Section 2 - Responsibilities
We, as data controller, are responsible for ensuring that this notice is made available to you prior to us collecting/processing your personal data.
The privacy and security of your personal information is very important to us so we want to assure you that your information will be properly managed and protected when it's in our hands. Please read this notice carefully as it explains how we, and/or carefully selected third parties we work with, collect and use your personal information.
These terms may apply in addition to other privacy notices or terms we inform you of in specific circumstances when we are collecting or processing personal data.
Section 3 - Privacy Notice
Who are we? - Golden Charter are a pre-paid funeral plan provider and owned by a UK-wide national association of independent funeral directors. If you would like to contact us about the personal data we hold on you please write or email using the information below.
Contact Name: The Data Controller
Address: Golden Charter, 10 Canniesburn Drive, Bearsden, Glasgow, G61 1BF
Email: regulatorycompliance@goldencharter.co.uk
What is personal data? - Under the UK’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Special category data is personal data which the GDPR says is more sensitive and so needs more protection. For example, information about an individual’s race, ethnic origin, religion or health are all considered special categories of data. The special categories of personal data Golden Charter might process are:
Religious preferences: We use this to ensure any religious funeral preferences you may have are met.
Any medical conditions relayed to us: This information will be used to improve our service, and allow us to provide potentially vulnerable customers with the support they need.
Unless there is another lawful basis for the processing, consent is required for Golden Charter to process both types of personal data, but it must be explicitly given. We will always tell you clearly why and how the information will be used. You may withdraw consent at any time by contacting us.
If you would like more information on UK-GDPR or the Data Protection Act 2018 and how it impacts you, this can be found on the Information Commissioner’s Office (ICO) website at ico.org.uk.
The personal data we would like to collect from/process about you (and the source if not collected directly from you, the data subject) is:
Your name, address, date of birth, telephone number and email contact
Your preferences with regards to your funeral plan
Your religious preferences if appropriate (this is also classed as special category data as above)
If you decide to have a nominated representative, we will ask you for their name and address to provide them with details of your funeral plan
Any medical conditions relayed to us: This information will be used to improve our service, and allow us to provide potentially vulnerable customers with the support they need.
If you purchase a plan from one of our Appointed Representatives or are referred to us by our Introducer Appointed Representatives we will use the personal data you give them.
The personal data we collect will be used for the following purposes:
Creating a quotation for a funeral plan product
Administration of your Golden Charter product including passing your information to a funeral director for the contractual provision of our service. This may include the funeral director retaining records of the transaction
Providing you with a copy of your demands and needs document and funeral plan summary
If you decide to have a nominated representative, we will provide them with details of your funeral plan
Marketing of our products and services
Creating a quotation for a funeral plan product
Carrying out customer satisfaction surveys and market research
To monitor visitors to our website and responses to marketing campaigns
To answer enquiries from you including social media and web chat
To undertake general analysis of the demographics of our customer and enquirer base
To protect our customers against fraud and other kinds of financial crime. We may pass on your details to fraud prevention agencies, where we have a legal obligation to do so
Administration of our legacy legal services products
We collect personal data from visitors to our website through the use of online forms. We also collect information about the transactions you undertake through the site, including details of bank accounts to be used for payments. If a payment card is used, a secure third party payment processor facilitates this payment. This third party only provides us with limited details of any card you use.
We collect additional information automatically about your visit to our website through the use of cookies. A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser.. Find out more about cookies on ico.org.uk/for-the-public/online/cookies
We use cookies to identify you when you visit this website and to keep track of your browsing patterns.
We are committed to safeguarding the privacy of our website visitors, service users, and individual customers. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the collection and sharing of your personal data. We use Cookie First for cookie management – to access our privacy controls or amend your preferences, please click the blue circle icon in the bottom left of your screen to view. If at any point you would like to opt-out of receiving marketing communications from us, or would like to change the channels (such as email, post or telephone) that we use to contact you, please contact us by one of the methods shown above.
Our legal basis for processing your personal data may be classed as one of the categories below:
Provision of a contract
Consent
Legitimate interest
Any legitimate interests pursued by us are for our own purposes and we do not share your details with any third parties for marketing purposes.
If you purchased a funeral plan before 29th July 2022 and your payments are payable to an insurer, the insurer will become data controller in respect of the data you have provided for your payments.
Section 4 - Sharing your data
Will Golden Charter share my personal data with anyone else? We will pass your personal data on to third-party service providers contracted to Golden Charter in the course of dealing with you. This may include special categories of data where appropriate. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil your funeral plan or legal services product. When they no longer need your data to fulfil this service, they will dispose of the details in line with Golden Charter’s procedures. If we wish to pass your special categories of data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise. See below for more information on the types of third parties.
Section 5 - Who do we share with?
At Golden Charter we will pass your personal data to third parties. Third parties who work with us are contractually bound to adhere to Data Protection legislation and act in compliance with our instructions. The following third parties will receive your personal data for the following purpose(s) as part of the processing activities:
Funeral director→ The funeral director needs to know your details to allow them to arrange your funeral when you pass away. They may also be given details of your nominated representative or next of kin if you provide them to ensure they are acting in accordance with your wishes. Funeral directors are allocated plans shortly after the time of purchase so a funeral director will hold your data for a period of time. Funeral directors that work with Golden Charter are bound by our contractual agreement with them, where relevant, and/or our funeral plan terms and conditions.
Insurance provider → if you purchased a funeral plan before 29 July 2022 and you pay your funeral plan by Fixed Monthly Payments or by Single Premium, we have passed your personal data to an insurance provider to set up a life assurance policy in your name.
Fulfilment companies → These are companies who will print and send our marketing and post purchase paperwork.
Introducers → If you were introduced to Golden Charter via an approved Appointed Representative or Introducer Appointed Representative, we will, as part of fulfilling our contractual obligations, pass certain information to them including your name, plan number and plan status.
Third party payment processors → For any purchases you make using a payment card, we use a third party payment processor to take this payment.
The Golden Charter Trust → For administration of your funeral plan. We have a robust agreement providing that all data must be used in accordance with your rights and Data Protection legislation.
Barnett Waddingham → For administration of funds within the Golden Charter Trust and facilitating their role as actuaries of the Golden Charter Trust. If you would like more information about Barnett Waddingham and their own privacy notice please see their website www.barnett-waddingham.co.uk.
Third party suppliers → All third party suppliers provide goods or services, including data analytical services.
Digital Services → From time to time we will seek the assistance of select third parties who help with advertising on our website and tracking/reporting website visitors. If you consent then it is likely that certain data which may be classified as personal data, e.g. your IP address, will be able to be accessed by the likes of Google’s Double Click and Google Analytics
Government industry bodies → We may be required by law to share your personal information with fraud prevention organisations, law enforcement bodies or courts or those involved in legal processes
Section 6 - Retention Period
We will process personal data for the length of time required to fulfil our obligations contractually or legally.
We will process (collect, store and use) the information you provide in a manner compatible with the UK’s General Data Protection Regulation (GDPR).
We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Golden Charter is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Section 7 - International transfers of your personal data
Information may be transferred internationally to other countries around the world, including countries that do not have data protection laws equivalent to those in the UK. We have security measures in place to seek to ensure that there is appropriate security for information we hold.
Section 8 - Your right as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
Right of access - you have the right to request a copy of the information that we hold about you.
Right of rectification - you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten - in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing - you have the right to request to restrict the processing of your data, where certain conditions apply.
Right of portability - you have the right to have the data we hold about you transferred to another organisation. We will endeavour to provide you with the detail we hold on you to allow you to take it to another organisation. This may be limited by technological requirements.
Right to object - you have the right to object to the processing of your data in certain circumstances, such as direct marketing.
Right to object to automated processing, including profiling - you also have the right to be subject to the legal effects of automated processing or profiling.
Right to judicial review - in the event that we refuse your request under rights of access, we will provide you with a reason why. You have the right to complain as outlined in the section below.
All of the above requests will be forwarded on should there be a third party involved in the processing of your personal data.
Can I find out the personal data that Golden Charter holds about me? Yes, we, at your request, can confirm what information we hold about you and how it is processed. In order to do this please write to The Data Controller, Golden Charter, Canniesburn Gate, 10 Canniesburn Drive, Bearsden, Glasgow G61 1BF. Alternatively you can email your request to regulatorycompliance@goldencharter.co.uk .
We may ask for verification in order to fulfil your request.
Section 9 - Complaints
In the event that you wish to make a complaint about how your personal data is being processed by us (or third parties as described above), please contact our Customer Resolution Team on 0800 171 2955 or email customer.resolution@goldencharter.co.uk.
If you are unhappy with how your complaint has been handled, you have the right to lodge a complaint with Golden Charter’s Chief Risk & Compliance Officer.
You also have the right, if you are still not satisfied with how we have handled your personal data, to contact the supervisory authority, the Information Commissioner’s Office (ICO).
The details for each of these contacts are:
Contact Name: Chief Risk & Compliance Officer
Address: Golden Charter, 10 Canniesburn Drive, Bearsden, Glasgow, G61 1BF
Email: regulatorycompliance@goldencharter.co.uk
Telephone: 0800 111 4514
Contact Name: Information Commissioner’s Office
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Email: casework@ico.org.uk
Telephone: 0303 123 1113
Other websites linked on our site
Our website may contain links to other websites that are outside our control and are not covered by this Privacy Policy. If you access other sites using the links provided, the operators of these sites may collect information from you that will be used by them in accordance with their privacy policy, which may differ from ours.
Amendments
Please note that this Privacy Policy is subject to change from time to time. It was last updated on 1 October 2024.
If you have any questions regarding our Privacy Policy, please contact us by emailing contact@goldencharter.co.uk or calling 0800 833 800.
