Privacy Policy

Fosters takes data privacy seriously. We recognise and value the trust that individuals place in us when providing us with personal data and we are committed to safeguarding the privacy and security of personal data we may collect from visitors to our websites and/or the clients to whom we provide funerals, funeral plans and other services.

This Privacy Policy aims to help you understand our personal data collection, usage and disclosure practices by explaining:

  1. Who we are and what we do
  2. What personal data we collect about you
  3. How we obtain the personal data about you
  4. How we use your personal data
  5. Who we share your personal data with
  6. Which countries we transfer your personal data to
  7. How long we keep your personal data
  8. How we protect your personal data
  9. What rights you have in relation to your personal data
  10. Who is the data controller of your personal data
  11. How we use cookies and similar technologies
  12. How you can contact us
  13. How we may update this Privacy policy
  14. Making a complaint

By providing your personal data to us (whether via one of our websites, by email, in person or over the phone), you agree to the processing set out in this Privacy Policy. Further notices highlighting certain uses we wish to make of your personal data, together with the ability to opt in or out of selected uses, may also be provided to you when we collect personal data from you.

Please note: This Privacy Policy does not apply to, and Fosters is not responsible for, any third-party websites which may be accessible through links from this website. If you follow a link to any of these third-party websites, they will have their own privacy policies, and you will need to check these policies before you submit any personal data to such third-party websites.

1. Who we are and what we do

Fosters Family Funeral Directors is a trading name of THE INDEPENDENT FAMILY FUNERAL DIRECTORS LTD, a company incorporated in Scotland with registered number SC391536 and with its registered office at 147 St. Georges Road, Glasgow, G3 6LB (“Fosters”, “We”, “Our”). We provide funeral and funeral-related services, as well as funeral pre-payment planning services. Fosters is authorised and regulated by the Financial Conduct Authority to enter into and carry out funeral plan contracts FRN 966550.

Please see “Who is the data controller of your personal data” below for more information on the entities that control and process personal data within Fosters.

2. What personal data we collect about you

2.1 We may collect and process different types of personal data in the course of operating our business and providing our services. These include:
2.1.1 Basic personal details such as your name;
2.1.2 Contact data such as your telephone number and postal or email address;
2.1.3 Financial data such as payment-related information or bank account details;
2.1.4 Demographic data such as your address, preferences or interests;
2.1.5 Website usage and other technical data, such as details of your visits to our websites or information collected through cookies and other tracking technologies;
2.1.6 Personal data provided to us by or on behalf of our clients or generated by us in the course of providing our services, which may, where relevant, include special categories of personal data;
2.1.7 Identification and other background verification data such as a copy of passports or utility bills or evidence of beneficial ownership or the source of funds to comply with client due diligence/”know your client”/anti-money laundering laws and collected as part of our client acceptance and ongoing monitoring procedures;
2.1.8 Recruitment-related data such as your curriculum vitae, your education and employment history, details of professional memberships and other information relevant to potential recruitment to Fosters;
2.1.9 Data that you may provide to us in the course of registering for and attending events or meetings, including access and dietary requirements; and
2.1.10 Any other personal data relating to you that you may provide.

3. How we obtain personal data about you

We may collect or receive your personal data in a number of different ways:
3.1 Where you provide it to us directly, for example, by corresponding with us by email or via other direct interactions with us such as completing a form on our website or registering for and using one of our online tools such as the funeral cost calculator;
3.2 Where we monitor the use of, or interactions with, our websites, any marketing we may send to you, or other email communications sent from or received by Fosters;
3.3 Third-party sources, for example, where we collect information about you to assist with “know your client” checks as part of our funeral plan application procedures or where we receive information about you from recruitment agencies for recruitment purposes; or
3.4 Publicly available sources – we may, for example, use such sources to help us keep the contact details we already hold for you accurate and up to date or for professional networking purposes, e.g. LinkedIn.

4. How we use your personal data

We will only use your personal data where we are permitted to do so by applicable law. Under EU and UK data protection law, the use of personal data must be justified under one of a number of Legal basis. The principal Legal basis that justify our use of your personal data are:

4.1 Contract performance: where your information is necessary to enter into or perform our contract with you.
4.2 Legal obligation: where we need to use your information to comply with our legal obligations.
4.3 Legitimate interests: where we use your information to achieve a legitimate interest, and our reasons for using it outweigh any prejudice to your data protection rights.
4.4 Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.
4.5 Consent: where you have consented to our use of your information (you will have been presented with a consent form or facility in relation to any such use and may withdraw your consent at any time by notifying Us of your desire to do so.
We may use your personal data in the following ways. In each case, we note the grounds that we rely on to use your personal data.
4.6 To provide our funeral, funeral related services and other services to you and to conduct our business – to administer and perform our services, including to carry out our obligations arising from any agreements entered into between you and us (please note that our Standard Terms of Business apply where we provide funeral services); Legal Basis: contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you), consent.
4.7 To facilitate the use of our websites and to ensure content is relevant – to respond to requests for information or enquiries from visitors to our websites and to ensure that content from our websites is presented in the most effective manner for you and for your device;
Legal Basis: legitimate interests (to allow us to provide you with the content and services on the websites), consent, contract performance.
4.8 For marketing and business development purposes – to provide you with details of new services, promotions, and funeral updates. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you, or you may opt out by contacting us as set out in section 12 below; Legal basis: legitimate interests, consent.
4.9 For research and development purposes – analysis to better understand your and our clients’ services and marketing requirements and to better understand our business and develop our services and offerings; Legal basis: legitimate interests (to allow us to improve our services).
4.10 For recruitment purposes – to enable us to process applications for employment submitted via the Careers section of our website and to assess your suitability for any position for which you may apply at Fosters; Legal basis: legitimate interests (to ensure that we can make the most appropriate recruitment decisions for Us), contract performance (in order for us to take steps at your request to enter into a contract with you).
4.11 To fulfil our legal, regulatory, or risk management obligations – to comply with our legal obligations (performing client due diligence/”know your client”, anti-money laundering, anti-bribery, sanctions or reputational risk screening, identifying conflicts of interests); for the prevention of fraud and/or other relevant background checks as may be required by applicable law and regulation and best practice at any given time (if false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and may be recorded by them or by us); to enforce our legal rights, to comply with our legal or regulatory reporting obligations and/or to protect the rights of third parties; Legal basis: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities, to ensure that you fall within our acceptable risk profile and to assist with the prevention of crime and fraud). Where we process special categories of personal data, we may also rely on substantial public interest (prevention or detection of crime) or legal claims.
4.12 To ensure that we are paid – to recover any payments due to us and, where necessary, to enforce such recovery through the engagement of debt collection agencies or taking other legal action (including the commencement and carrying out of legal and court proceedings);
Legal basis: contract performance, legal claims, legitimate interests (to ensure that we are paid for our services).
4.13 To inform you of changes – to notify you about changes to our services or our Standard Terms of Business for funeral or funeral-related services or this Privacy policy; Legal basis: legitimate interests (to ensure we can notify you about changes to our service, Standard Terms of Business etc.).
4.14 To reorganise or make changes to our business -If we undergo a re-organisation (for example, if we merge, combine or divest a part of our business), we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process or transfer to that re-organised entity or third party your personal data for the same purposes as set out in this Privacy Policy or for the purpose of analysing any proposed re-organisation;
Legal basis: legitimate interests (to allow us to change our business).

5. Who we share your personal data with

We may share your personal data with a variety of the following categories of third parties:

5.1 Our professional advisors (e.g. legal, financial, business, risk management or other advisors), bankers and auditors;
5.2 Our insurers and insurance brokers;
5.3 Third-party service providers, including a legal services firm based in Glasgow, Scotland, who may be engaged to offer advice to you, or carry out legal services pursuant to a funeral plan contract, funerals and other related services.
5.4 Other third-party external advisors, suppliers or experts engaged in the course of the services we provide to our clients and with their prior consent, such as advocates, solicitors and technology service providers.

We may also process your personal data to comply with our regulatory requirements or in the course of dialogue with our regulators as applicable, which may include disclosing your personal data to government, regulatory or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, or unless doing so would prejudice the prevention or detection of a crime, we will direct any such request to you or notify you before responding.

6. Which countries we transfer your personal data to

We cannot limit our processing of an individual’s personal data to the country in which that individual is based. While providing our services, we may need to transfer personal data to locations outside the jurisdiction in which you provide it or where you are viewing our website. If you are based in the UK, this may mean we may have to process data in a third-party area such as the EEA or United States or other countries in which data protection laws may not be as comprehensive as in the UK.

Regardless of the location of our processing, we will impose the same data protection safeguards that we deploy inside the UK.

7. How long we keep your personal data

We will retain your personal data for as long as is necessary to fulfil the purpose for which this data was collected, and any other permitted linked purpose (for example, certain transaction details and correspondence related to any services we provide may be retained until the time limit for claims in respect of the transaction has expired or to comply with regulatory requirements regarding the retention of such data). If your personal data is used for two purposes, we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires. Our retention periods are also based on our business needs and good practice.

8. How we protect your personal data

We recognise that information security is an integral element of data privacy. While no data transmission (including over the Internet or any website) can be guaranteed to be secure from intrusion, we implement a range of commercially reasonable physical, technical and procedural measures to help protect personal data from unauthorised access, use, disclosure, alteration or destruction in accordance with data protection law requirements.

Information that you provide to us is stored on our or our service providers’ secure servers and accessed and used subject to our security policies and standards or those agreed with our service providers.

Everyone at Fosters and any third-party service providers we may engage that process personal data on our behalf (for the purposes listed above) are also obligated to respect the confidentiality of personal data.

Alongside our role, please also note that where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites or online services, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share a password with anyone.

9. What rights you have in relation to your personal data

If you have any questions about our use of your personal data, you should first contact us via the details provided in section 12 below. Under certain circumstances and in accordance with the GDPR or other applicable data protection laws, you may have the right to require us to:

9.1 provide you with further details on the use we make of your information
9.2 provide you with a copy of the information that we hold about you;
9.3 update any inaccuracies in the personal data we hold;
9.4 delete any personal data that we no longer have a lawful ground to use;
9.5 where processing is based on consent, to withdraw your consent so that we stop that particular processing;
9.6 object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
9.7 restrict how we use your information whilst a complaint is being investigated.

You may also ask us not to process your personal data for marketing purposes. We will inform you if we intend to disclose your information to any third-party service provider for this purpose. As indicated in section 4 above, you can exercise your right to prevent such processing at any time by contacting Us.

We are also required to take reasonable steps to ensure that your personal data remains accurate. In order to assist us with this, please let us know of any changes to the personal data that you have provided to us by contacting us at customerservice@fostersfuneraldirectors.com.

While it is our policy to respect the rights of individuals, please be aware that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and some of these rights may be limited (for example the right to withdraw consent) where we are required or permitted by law to continue processing your personal data to defend our legal rights or meet our legal and regulatory obligations.

If you contact us to exercise any of these rights, we will check your entitlement and respond, in most cases, within a month.

If you are not satisfied with our use of your personal data or our response to any exercise of these rights, you have the right to complain to the Information Commissioners Office by:

Our ICO Registration number is ZA565305. Our ICO registry record is found at https://ico.org.uk/ESDWebPages/Entry/ZA565305

10. Who is the data controller of your personal data

The Independent Family Funeral Directors Ltd.

11. How we use cookies and similar technologies

We collect data when you sign up for our services and when you browse our site. This information is used to provide our services, and advertising and analyse how visitors engage with our website.

When you submit a form using our site, we may collect the following personal data:

  • Your name
  • Your email address
  • Your phone number
  • Your address
  • Other relevant personal information

When you use our website, we may also use cookies or similar technology to collect extra data, including:

Your IP address – a numerical code to identify your device which can provide information about the country, region or city where you are based.

Your browsing history of the content you have visited on our site, including information on how you were referred to our site via a third-party website.

Details of your device, such as unique device ID, unique advertising ID and browsers used to access our content.

12. How you can contact us

We have designated a Data Protection Officer. They are responsible for promoting awareness of the GDPR across the organisation, assessing our GDPR readiness, identifying any gap areas and implementing the new policies, procedures and measures.
Our Data Protection Officer is:

DPO, Fosters Family Funeral Directors,
147 St George’s Rd,
Glasgow
G3 6LB

This means they are responsible for deciding how and why we hold and use your personal data.

If you have any questions about our GDPR practices or you have a complaint, please contact our Data Protection Officer. You can write to them at the address above or email dpo@fostersfuneraldirectors.com if you have any further questions.

13. How we may update this Privacy policy

We may change the content of our websites and how we use cookies without notice, and consequently, our Privacy Policy may change from time to time in the future. We therefore encourage you to review them when you visit the website to stay informed of how we are using personal data.

This Privacy policy was last updated in October 2023.

14. Making a complaint

We are committed to ensuring the security and protection of the personal information that we process and to provide a compliant and consistent approach to data protection.

We always aim to provide the highest possible standards of service. We do, however, appreciate that, from time to time, things can go wrong. If we do not meet your expectations or you are dissatisfied with the service we have provided, then we want to hear from you.

How to make a complaint

We aim to ensure that:

• Making a complaint is as easy as possible
• We deal with your complaint promptly and in confidence
• You receive a fair outcome
• We learn from complaints and use the feedback to improve our service

You can make a complaint by the following methods:

• In writing: DPO Complaint, Fosters Family Funeral Directors, 147 St George’s Rd, Glasgow G3 6LB
• By e-mail: dpo@fostersfuneraldirectors.com
• By telephone: 0800 121 8090

Lines are open 09.00-18.00 Monday to Friday and 09.00-13.00 on Saturday.

We will:

• Acknowledge your complaint within 5 working days of receipt
• Investigate your complaint and aim to provide a final response within one month but no later than three months from the date of receipt.
• If we are unable to resolve your complaint within one month we will provide you with a written update on why we need the extra time.

What to do if you are not happy with the outcome of your complaint in relation to the way we have handled your personal data

We want to resolve your complaint relating to Personal Data handling and provide you with a fair outcome. If we can’t reach an agreement, you can refer your complaint to the ICO by either calling their helpline on 0303 123 1113 or by visiting https://ico.org.uk/make-a-complaint/.

Our ICO Registration number is ZA565305.
Our ICO registry record is found at https://ico.org.uk/ESDWebPages/Entry/ZA565305