PREPAID FUNERAL PLAN TERMS & CONDITIONS

1. INFORMATION ABOUT US
   
   
   
   1. Who are we; “We” or “us” are Independent Funeral Planning Services Limited (Company Number 13556844) with registered office at 63 High Bridge, Newcastle upon Tyne, NE1 6BX. We will be your Funeral Plan Provider responsible for administering your Funeral Plan. We are authorised and regulated by the Financial Conduct Authority to sell funeral plans. You can find us on the Financial Services Register which can be viewed at https://register.fca.org.uk. Our Firm Reference Number (FRN) is: 962434. We are not a Funeral Director, or funeral services provider. We work with a network of providers to carry out our plans, some of whom are our Appointed Representatives. This means they are authorised to sell our plans, should you wish to buy from them directly.
      
      The funeral director the Funeral Plan relates to, will be referenced on your application at time of purchase.
   
   
   2. In these terms and conditions:
      
      “Administration Fee” means the charge payable by you in accordance with the provisions of these terms and conditions (being £295 for all plans taken out from 29th July 2022). See 3.6 for more information on total plan pricing.“Application” means the application form you have completed, signed, and returned to us.
      
      “Appointed Representative” means an authorised representative appointed to sell Funeral Plans on our behalf. We may appoint additional Appointed Representatives from time to time.
      
      “Business Day” means any day other than a Saturday or Sunday or a public or bank holiday in the United Kingdom.
      
      “Covered Individual” means the person named within the Funeral Plan Summary on whose death a funeral is covered by the Funeral Plan (who may also be you).
      
      “Disbursements” means third-party costs that are outside of your funeral directors control, such as crematorium fees, ministers fees and doctors’ fees. You can choose to guarantee these costs within your plan or pay a contribution towards them. If a plan has been purchased with a contribution towards disbursements, you should be aware that these costs may increase over time. This will mean that at the time of need, any shortfall must be paid from your Estate.
      
      “Estate” means the Covered Individual’s next of kin, executors, trustees and/or representative who are legally authorised to act for the Covered Individual after his or her death.
      
      “Funeral Pack” means the documentation supplied by us to you containing the Funeral Plan Summary, the Nominated Representative document (if any), a copy of these terms and conditions and our privacy notice.
      
      “Funeral Plan Contract” the contract between you and us to carry out the Funeral Plan in accordance with the documents set out at clause 2.1.
      
      “Funeral Plan Statement” means a statement sent to you every 3 years providing you with details of the Funeral Plan.
      
      “Funeral Plan Summary” the separate document summarising the details and main terms of the chosen Funeral Plan.
      
      “Funeral Plan” means the funeral plan agreed in the Application and identified in the Funeral Plan Summary.
      
      “Guaranteed Disbursements” means the third-party costs that are guaranteed to be covered in your chosen funeral plan.
      
      “Moratorium Period” means the period in which you, if applicable, are paying instalments to us for the Funeral Plan during which we are not obliged to provide, or secure the provision of, a funeral on death. For the avoidance of doubt, the Moratorium Period ends on the day you pay your final instalment, or your balance is cleared, whichever is first.
      
      “Nominated Representative” means, if applicable, the individual you have chosen to be made aware of the Funeral Plan and whom we will contact on your death (or the death of the Covered Individual as the case may be).
      
      “Trust” means The Independent Funeral Planning Services Trust (or for plans taken out before 29th July 2022, the Go As You Please Funeral Plan Trust) administered by The Funeral Trustee Company Limited (CRN: 08772699) whose registered office is at 63 High Bridge, Newcastle Upon Tyne, United Kingdom, NE1 6BX.
      
      “you/your” the applicant/person applying for the Funeral Plan (you may also be the Covered Individual).
   
   
   
   


2. OUR CONTRACT WITH YOU
   
   
   
   1. The following documents make up the agreement between you and us:
      
      
      
      1. the signed Application,
      
      
      2. the Funeral Plan Summary, and
      
      
      3. these Terms and Conditions.
      
      
      
      
   
   
   2. Our Contract. We (or our Appointed Representative) will provide you with the Funeral Plan Summary once we have received your signed Application and Administration Fee. We will issue you with the formal Funeral Pack within 14 days, identifying the Funeral Plan chosen, at which point the Funeral Plan Contract will come into existence between you and us.
   
   
   3. Upon receipt of your Funeral Pack, please check that all information is correct, and inform us of any errors within 30 days.
   
   
   4. Your contact details. If we have to contact you, we will do so by telephone or by writing to you at the email address or postal address you provided to us in your Application.
   
   
   5. The Funeral Plan Statement. Once every 3 years from the date of the Funeral Plan Contract, we will send you at the email address or postal address you provided to us in your Application, the Funeral Plan Statement summarising your Funeral Plan.
   
   
   6. Nominated Representative. Unless you have expressly stated in the Application that you do not want us to contact your Nominated Representative or that no Nominated Representative is to be appointed, we will provide your Nominated Representative with an explanatory document within 5 Business Days of issue of the Funeral Plan Contract.
   
   
   
   


3. THE FUNERAL PLAN
   
   
   
   1. Eligibility. The Funeral Plans are available to UK residents who are aged 50 or over at the date of application. We may accept applications for UK residents under 50 at our sole discretion.
   
   
   2. Plan Types. Our Funeral Plans are created on a bespoke basis in conjunction with our Appointed Representative Funeral Directors to reflect local pricing and their particular selection of products and services. These are offered with either a fixed contribution towards disbursements, or on a fully guaranteed basis for a supplement of up to £250 depending on your local area. Guaranteed disbursements will be specified by the Funeral Director but may typically include crematorium fees, minister fees and doctors’ fees.
   
   
   3. What the Plan covers. The Funeral Plan purchased shall include those products and services set out in the personalised Funeral Plan Summary included in the Funeral Pack.
   
   
   4. What Our Plans do not cover. The cost for products and services which will not be included in the Funeral Plan may include, but are not limited to:
      
      
      
      1. 
         
         
         
         1. (a) a memorial (for example, headstone), flowers, additional limousines, press notice and order of service,
         
         
         2. (b) catering,
         
         
         3. (c) any fees payable to a coroner,
         
         
         4. (d) the use of an organist, choir or live music,
         
         
         5. (e) any costs incurred to remove a medical device (for example, a pacemaker) or a prosthesis (for example, an artificial limb),
         
         
         6. (f) conducting the funeral on a weekend, at an unusual hour or public holiday,
         
         
         7. (g) burial services and purchasing a burial plot,
         
         
         8. (h) repatriation costs,
         
         
         9. (i) special wishes,
         
         
         10. (j) a person to officiate such as a religious minister (other than our nominated humanist minister),
         
         
         11. (k) cost of a church service, and
         
         
         12. (l) embalming.
         
         
         
         
      
      
      
      

      We cannot reasonably calculate those charges in advance and therefore, if they are required, they will need to be paid for separately by your Estate before the funeral takes place. You can make a “contribution towards” these costs at any time, and the contribution will be added to your Funeral Plan. Please note, these charges are not included in our definition of “Disbursements”.

   
   
   5. Price Guarantee. Where the price of your chosen plan includes guaranteed disbursements, and this is expressly confirmed within your Funeral Plan Summary, we guarantee to pay those disbursement costs at the time of the funeral. If you have elected not to guarantee disbursements and only contribute an amount towards them, your funeral costs are not guaranteed, and we shall have no liability for third party costs that exceed your contribution at the time of the funeral.
   
   
   6. Total Price. The total price of our plans includes the wholesale cost in providing your chosen funeral plan paid by us to the Funeral Director, plus our administration fee of £295 for arranging and establishing the plan (our administration fee reflects our actual business costs in setting up the plan); we also charge a £250 management fee to manage and maintain the plan until the time of need, which includes a small inflationary cushion. This means there is a £545 difference in our at-need funerals than the equivalent pre-paid plan price.
   
   
   
   


4. YOUR RESPONSIBILITIES
   
   
   
   1. How you can pay. You can pay for the Funeral Plan in full by bacs, cheque, credit or debit card or in instalments by standing order over 12 months (please see below regarding paying by instalments). Our Appointed Representatives may take payment from you as our agent but the payment will be made directly to us.
   
   
   2. Who can pay. Another person can pay for your Funeral Plan but if they don’t pay, you are still responsible. You will own and control your Funeral Plan and will receive the documents relating to it.
   
   
   3. Change of details. Please let us know if you or the Covered Individual under the Funeral Plan (if different) change your or their name, address, or any other information that may affect your Funeral Plan.
   
   
   4. The Applicant. If you are the Covered Individual, the rights and benefits set out in our contract with you accrue to you and you are responsible for making payments to us in accordance with our contract. If you have named a different person as the Covered Individual on the Application, the rights and benefits set out in our contract with you will nevertheless accrue to you and not to the Covered Individual.
   
   
   5. Change of funeral location. The Funeral Plan provides for your funeral to be provided at the location specified in the Application. If you change your address, you must notify us, and we will have the right to nominate an appropriate alternative funeral director or cancel the Funeral Plan in accordance with clause 7.7.3. If, notwithstanding the change of address, you or your Estate wish the funeral to be undertaken by us then you or your Estate will be responsible for any additional transport costs (beyond a 20mile radius) incurred in connection with the funeral. Additional mileage, if applicable, is charged per mile at our rate applicable at the date of the funeral.
   
   
   
   


5. PAYMENT BY INSTALMENTS
   
   
   
   1. Instalments. The maximum period available to you will be 12 months and there are no additional charges for using such payment option. You will pay the instalments by standing order.
   
   
   2. Paying off early. You can make one-off extra payments on any instalment plan at any time to reduce your balance or you can pay the rest of the balance on your Funeral Plan at any time.
   
   
   3. If you fail to pay. If you have a payment shortfall of two consecutive payments, we will provide you with a statement of the payments due, the total amount of the shortfall and information on the consequences under the Funeral Plan Contract if the payment shortfall is not paid within 10 Business Days of the notification.
   
   
   4. If you die before all payments are made. Should the Covered Individual pass away prior to full payment of the Funeral Plan, the cost and arrangements detailed in the Funeral Plan Summary will still be honoured, and we will credit the amount you have contributed (less the Administration Fee) towards the cost of the funeral. The outstanding balance will need to be paid for by your Estate at the time of the funeral. Alternatively, the Estate can choose not to pay the balance and the Funeral Plan will be deemed to be cancelled. If this is the case, we will return the instalments paid on the Funeral Plan to the Estate less the Administration Fee in accordance with clause 7.6.
   
   
   
   


6. OUR RESPONSIBILITIES
   
   
   
   1. How we keep your money safe. All Funeral Plan costs to cover your funeral (those to be paid to the funeral director at the time of need) are passed to the Trust to be held in a secure account in accordance with the Trust deed. This money is held in the Trust from the time that you pay us.
   
   
   2. Appointment of Agent. You irrevocably appoint us for the duration of the Funeral Plan Contract as an agent for the purpose of asserting any right or interest you may have in the Trust, such appointment being without prejudice to the possibility of you or the Covered Individual asserting your/his/her rights or interests yourself/themself.
   
   
   3. Release of funds. Upon supply of proof of death to us by your Estate, we will pass such documentation to the Trust who will then release the funds to us for the execution of your funeral by your funeral director.
   
   
   4. Substitution. We reserve the right to substitute any of the goods or services specified in the Funeral Plan Summary with an equivalent alternative at no further charge should the goods and services specified be unavailable when required.
   
   
   5. What if we or our Appointed Representatives go out of business? If we are unable to provide the Funeral Plan under the Funeral Plan Contract the money will be protected by the Trust under the control of the independent trustee. The trustee will work with the Financial Conduct Authority (or equivalent regulatory body) for a replacement funeral provider to provide your Funeral Plan Contract. Alternatively, the funds will be returned to the person purchasing the Funeral Plan, or (if this is you), after your death, to your Estate. You or the Estate also have the right to make a claim from the Financial Services Compensation Scheme (FSCS) if your Funeral Plan hasn’t already been carried out. You can find out more by visiting www.fscs.or.uk or contacting the scheme directly by post: Financial Services Compensation Scheme, PO Box 300, Mitcheldean, GL17 1DY or by telephone: 0800 678 1100 or 0207 741 4100.
   
   
   6. Consent. Further to clause 6.5, you hereby consent to the transfer of our obligations (towards you or, where appropriate, the Covered Individual) under the Funeral Plan Contract to another funeral plan provider in the event of our failure to carry out your Funeral Plan Contract, provided that this consent is only in relation to:
      
      
      
      1. transfers arranged by an insolvency practitioner appointed to us that will result in the Funeral Plan Contract being carried out by the transferee on the same terms at this Funeral Plan Contract you entered into with us; and
      
      
      2. transfers arranged by FSCS in securing continuity of the Funeral Plan Contract with consent to the contract being varied so as to result in the Funeral Plan Contract being carried out by the transferee on terms corresponding in all material respects (so far as it appears to the FSCS to be reasonable in the circumstances) to those which applied under the Funeral Plan Contract entered into with us.
      
      
      
      
   
   
   
   


7. CANCELLATION
   
   
   
   1. How you can cancel. You may cancel the Funeral Plan without giving any reason and without penalty within the “Cancellation Period” which is defined as either:
      
      
      
      1. (a) within 30 days of the date of receipt by you of the Funeral Pack; or
      
      
      2. (b) in the case of an instalment payment plan, within the Moratorium Period.
      
      
      
      
   
   
   2. If you do wish to cancel your Funeral Plan you must notify us, either:
      
      
      
      1. (a) by completing and returning the cancellation form entitled “Cancellation Form” which will be supplied upon request; or
      
      
      2. (b) by post to 63 High Bridge, Newcastle Upon Tyne, United Kingdom, NE1 6BX; or
      
      
      3. (c) by telephone on 07485 306607; or
      
      
      4. (d) by email to enquiries@the-ifps.co.uk; or
      
      
      5. (e) informing the Appointed Representative from whom you purchased the Funeral Plan.
      
      
      
      
   
   
   3. Any notification of cancellation should specify the Covered Individual’s name, your name (if different), your address, and the plan reference.
   
   
   4. Provided we receive such notification within the Cancellation Period, we will refund all the money you have paid within 30 days of us receiving notification of cancellation.
   
   
   5. If you wish to cancel the Funeral Plan after the Cancellation Period, you must notify us in the same manner as set out in clause 7.2 and we will refund any money you have paid, less the Administration Fee, within 30 days of us receiving notification of cancellation.
   
   
   6. Unless otherwise agreed any refunds shall be paid to the person purchasing the Funeral Plan.
   
   
   7. How we can cancel. We may cancel the Funeral Plan by giving notice to you if:
      
      
      
      1. you have a payment shortfall of 2 consecutive payments, we have notified you within 5 Business Days of the second missed payment and you have not paid the payment shortfall within 10 Business days of the date of that notification in accordance with clause 5.4,
      
      
      2. the Covered Individual dies within the Moratorium Period and the outstanding balance is not paid for by the Estate,
      
      
      3. the funeral is to be conducted at a location other than the location identified in the Funeral Plan Summary,
      
      
      4. the funeral cannot be performed because of circumstances outside of our control (for example, war, terrorism, or riot).
      
      
      
      
   
   
   8. If we cancel the Funeral Plan in accordance with clause 7.7, the Funeral Plan Contract is terminated and the cost of your Funeral Plan less the Administration Fee will be refunded to the person purchasing the Funeral Plan, or (if this is you), after your death, to your Estate, and we will have no further obligations to provide the benefit set out in the Funeral Plan.
   
   
   9. No interest or investment returns on payments made shall be payable in respect of refunds due to cancellation by either of us.
   
   
   10. Change of Funeral Plan. If during the life of your Funeral Plan you wish to amend your plan or change to a different plan, then you can upgrade or downgrade your plan at our sole discretion. No changes can be made to the Funeral Plan after the Covered Individual’s death unless the Covered Individual’s Estate agrees any changes and pays any additional costs to the funeral director directly, and subject always to the Covered Individual’s wishes expressed in the Application Form.
   
   
   11. Upgrades. The cost of any upgrade will be the difference between the prevailing Funeral Plan prices at the time the upgrade is made.
   
   
   12. Downgrades. If you request a downgrade, we will refund the difference between the price you paid for the Funeral Plan and the current price of the new plan. A downgrade is only available with the Covered Individual’s consent during their lifetime.
   
   
   13. If you make any changes set out in clauses 7.10 to 7.12, we will make the changes to the Funeral Plan Summary and send you a copy. If you are paying by instalments, your new instalments will reflect the changes you make.
   
   
   
   


8. COMPLAINTS
   
   
   
   1. If you have a complaint about us, please contact us directly in the first instance and we will acknowledge receipt of your complaint within 7 days. We will provide you with a final response, or written response indicating when we will give you a final response, within 8 weeks after our receipt of your complaint.
      
      Post: Independent Funeral Planning Services Limited
      
      63 High Bridge, Newcastle Upon Tyne, United Kingdom, NE1 6BX
      
      Tel: 07485 306607
      
      Email: enquiries@the-ifps.co.uk
   
   
   2. If your complaint cannot be resolved, you may refer it to the Financial Ombudsman Service https://www.financial-ombudsman.org.uk/. Their telephone number is 0800 023 4567.
   
   
   
   


9. DATA PROTECTION
   
   
   
   1. We will only process your personal data, the personal data of the Covered Individual (if different) and the personal data of the Nominated Representative in accordance with our Privacy Policy.
   
   
   2. When you provide information to us about the Covered Individual (if applicable) and/or the Nominated Representative you must have their permission to do so and have told them about how we will use their personal information.
   
   
   3. Please view our Privacy Policy for more information on how we handle your data.
   
   
   
   


10. VAT
    
    
    
    1. Apart from the specific instances referred to in clause 10.2 below, the Funeral Plan does not include VAT. However, if at the time of the funeral VAT is payable on the funeral service or any part of it then any increased costs will be payable by you (or other person arranging the funeral) to us.
    
    
    2. Some Funeral Plans do include a charge for VAT on certain items. If at the date of the funeral the rate of VAT has increased, then the Covered Individual or Estate will be liable for the increase which will be payable to us in accordance with their payment terms.
    
    
    
    


11. MISCELLANEOUS
    
    
    
    1. We may amend these terms from time to time and will give written notice to you of any material amendments which have been made.
    
    
    2. Each of the paragraphs of these terms operates separately. If any court or relevant authority decides that any of them are unlawful, the remaining paragraphs will remain in full force and effect.
    
    
    3. The Funeral Plan is personal to you, the person specified on the Funeral Plan Summary, and cannot be sold or used as security for a loan. We may consider a request in writing to either:
       
       
       
       1. (a) nominate a different Covered Individual or,
       
       
       2. (b) transfer your rights and obligations under these terms to a new Applicant,
       
       
       3. (c) In the event we grant our prior written consent to either of the above transactions, we will issue a new funeral plan contract for the new Covered Individual and/or Applicant (as applicable). This may incur a further administrative charge payable by you.
       
       
       
       
    
    
    4. English law applies to your Funeral Plan unless you live in Scotland or Northern Ireland. If you live in Scotland, Scots law will apply. If you live in Northern Ireland, the laws of Northern Ireland will apply.
    
    
    
    

PRIVACY POLICY

Introduction

Welcome to the Independent Funeral Planning Services Limited (“IFPSL”, “we”, “us”, “our”) privacy notice. IFPSL respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

You can view the policy on our website www.the-ifps.co.uk and we will provide you with a hard copy in your funeral pack. Please also use the Glossary at the end to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are
   
   

   Purpose of this privacy notice

   
   

   This privacy notice aims to give you information on how IFPSL collects and processes your personal data when you request a funeral plan from us or if you are named as a Nominated Representative by a plan holder.

   
   

   This website is not intended for children and we do not knowingly collect data relating to children.

   
   

   Who we are

   
   

   We are Independent Funeral Planning Services Limited (“IFPSL”, “we”, “us”, “our”). Our registered office at 63 High Bridge, Newcastle upon Tyne NE1 6BX (company number 13556844). For the purposes of applicable data protection and privacy laws, we are considered the “Data Controller” in respect of the personal data that we collect, use and manage in accordance with this privacy notice.

   
   

   We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

   
   

   Contact details

   
   

   Name of data privacy manager:       Malcolm Stalker

   
   

   Email address:                                      enquiries@the-ifps.co.uk

   
   

   Postal address:                                     63 High Bridge, Newcastle upon Tyne, NE1 6BX

   
   

   Telephone number:                            07485 306607

   
   

   You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

   
   

   Inform us of changes

   
   

   It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

   
   

   Third-party links

   
   

   Our website XXXXXX may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

   
   


2. The data we collect about you
   
   

   Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

   
   

   We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

   
   
   
   
   • Identity Data includes first name, maiden name, last name, marital status, title, date of birth and gender.
   
   
   • Contact Data includes address, email address and telephone numbers.
   
   
   • Financial Data includes bank account and payment card details.
   
   
   • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
   
   
   • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
   
   
   • Special Categories of Personal Data includes details about your race, ethnicity, religion, political beliefs, health or sex life/sexual orientation.
   
   
   
   

   If you fail to provide personal data

   
   

   Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a funeral plan). In this case, we may have to cancel the funeral plan you have with us but we will notify you if this is the case at the time.

   
   


3. How is your personal data collected?
   
   

   We use different methods to collect data from and about you including:

   
   
   
   
   • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in application forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
     
     
     
     • apply for our funeral plans;
     
     
     • request marketing to be sent to you; or
     
     
     • give us some feedback.
     
     
     
     
   
   
   • Indirect interactions. The plan holder may give us your Identity and Contact Data to make you aware of the funeral plan (you may be the “Nominated Representative”).
   
   
   • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
   
   
   
   

   Where you provide us with personal data about someone other than yourself (e.g. a Nominated Representative or someone on whose behalf you are arranging a funeral plan), you must obtain their freely given, informed consent before doing so.

   
   


4. How we use your personal data
   
   

   We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

   
   
   
   
   • Where we need to perform the contract we are about to enter into or have entered into with you.
   
   
   • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
   
   
   • Where we need to comply with a legal or regulatory obligation.
   
   
   
   

   Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

   
   

   Purposes for which we will use your personal data

   
   

   We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

   
   

   Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   

   Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
   To provide Funeral Plans ordered by you including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c)  Financial (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Explicit consent with regards to any Special Category Data
   To contact you if you are the Nominated Representative regarding the funeral plan	(a) Identity (b) Contact (c)  Financial	(a) Legal obligation (b) Necessary for our legitimate interests (to recover debts due to us)
   To make suggestions and recommendations to you about goods or services that may be of interest to you including events we may hold	(a) Identity (b) Contact (c) Technical	Necessary for our legitimate interests (to develop our products/services and grow our business)
   To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
   To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

   
   

   Marketing

   
   

   We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

   
   

   Promotional offers from us

   
   

   We may use your Identity and Contact Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

   
   

   You will receive marketing communications from us if you have requested information from us or purchased a funeral plan from us and, in each case, you have not opted out of receiving that marketing.

   
   

   Third-party marketing

   
   

   We will get your express opt-in consent before we share your personal data with any company outside IFPSL or the Appointed Representatives (see below at paragraph 5) for marketing purposes.

   
   

   Opting out

   
   

   You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

   
   

   Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a funeral plan purchase.

   
   

   Cookies

   
   

   You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

   
   

   Change of purpose

   
   

   We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

   
   

   If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

   
   

   Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

   
   


5. Disclosures of your personal data
   
   

   We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

   
   
   
   
   • Internal Third Parties such as The Independent Funeral Planning Services Trust administered by The Funeral Trustee Company Limited (CRN: 08772699) whose registered office is at 63 High Bridge, Newcastle upon Tyne NE1 6BX. This third party will hold your payments on trust.
   
   
   • Our Appointed Representatives. These are the companies who we appoint to be the funeral directors under your Funeral Plan:
   
   
   • Go As You Please Woodland Funerals Limited (CRN: 09275362)
   
   
   • Go As You Please 2009 Limited (CRN: 07024767)
   
   
   • Go As You Please Consett Limited (CRN: 10027614)
   
   
   • Go As You Please Funerals (Edinburgh) Limited (CRN: 10317330)
   
   
   • External Third Parties:
     
     
     
     • Service providers acting as processors who provide IT and system administration services.
     
     
     • Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
     
     
     • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
     
     
     
     
   
   
   • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
   
   
   
   

   We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

   
   


6. International transfers
   
   

   We do not transfer your personal data outside the United Kingdom.

   
   


7. Data security
   
   

   We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

   
   

   We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

   
   


8. Data retention
   
   

   How long will you use my personal data for?

   
   

   We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

   
   

   To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

   
   

   Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

   
   

   In some circumstances you can ask us to delete your data: see below for further information.

   
   


9. Your legal rights
   
   

   Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please view the glossary at clause 10 below for further details.

   
   

   If you wish to exercise any of the rights set out above, please contact us.

   
   

   No fee usually required

   
   

   You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

   
   

   What we may need from you

   
   

   We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

   
   

   Time limit to respond

   
   

   We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

   
   


10. Glossary
    
    

    LAWFUL BASIS

    
    

    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

    
    

    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

    
    

    Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

    
    

    YOUR LEGAL RIGHTS

    
    

    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.