1. Who we are

“Sewardstone Park Cemetery & Crematorium” is a trading name used by two related companies:

Sewardstone Burials Limited
Company number: 12014265
Responsible for burial, ashes interment and related cemetery services at Daws Meadow and the Garden of Firdaus.

Sewardstone Park Cemetery and Crematorium Ltd
Company number: 16279605
Responsible for cremation and associated crematorium services.

Both companies have the following registered office:

Unit 1 Netherhouse Farm
Sewardstone Road
Chingford
London E4 7RJ

Telephone: 0203 812 5555
Email: info@spcemetery.com

Each company is a separate data controller for the personal information it uses to provide its own services.

The companies act as joint controllers where they jointly determine how personal information is used, including in relation to:

• the operation of this website;
• general enquiries that have not yet been allocated to a particular service;
• shared administration and contact systems; and
• arrangements involving both burial and cremation services.

Our shared Privacy Lead coordinates privacy enquiries and requests on behalf of both companies. You can exercise your rights against either company by using the contact details above. This does not affect your right to deal directly with either company.

In this notice, “Sewardstone Park”, “we”, “us” and “our” refer to the relevant company or, where information is jointly handled, both companies.

2. Information we collect

Depending on your dealings with us, we may collect:

• your name, postal address, email address and telephone number;
• your relationship to the deceased;
• information about funeral, cremation, burial, ashes, memorial and ceremonial arrangements;
• grave ownership, exclusive right of burial and deed information;
• payment, invoice and transaction information;
• correspondence, enquiries, complaints and feedback;
• photographs, recordings, tribute material and livestream information;
• accessibility, mobility, dietary, religious or cultural requirements;
• information supplied by funeral directors, officiants, relatives, healthcare providers, coroners, registrars and public authorities;
• CCTV images if you visit premises covered by our cameras; and
• technical information about your use of our website, including IP address, browser, device and cookie preferences.

Information concerning religion, health or accessibility may be special-category personal information when it relates to a living person. We only use such information where necessary and where an additional legal condition applies, such as explicit consent.

Data-protection law generally does not apply to information relating solely to a deceased person. Nevertheless, we handle this information respectfully and securely, particularly where it also identifies or concerns living people.

3. How we obtain information

We may obtain personal information:

• directly from you through website forms, emails, telephone calls, visits and contracts;
• from relatives, representatives and other people arranging a funeral or memorial;
• from the other Sewardstone company where an enquiry or arrangement involves its services;
• from funeral directors, celebrants and religious officiants;
• from registrars, coroners, medical professionals and public authorities;
• from payment, media, livestreaming and other service providers; and
• automatically when you use our website, subject to your cookie choices.

Information concerning religion, health or accessibility may be special-category personal information when it relates to a living person. We only use such information where necessary and where an additional legal condition applies, such as explicit consent.

Data-protection law generally does not apply to information relating solely to a deceased person. Nevertheless, we handle this information respectfully and securely, particularly where it also identifies or concerns living people.

3. How we obtain information

We may obtain personal information:

• directly from you through website forms, emails, telephone calls, visits and contracts;
• from relatives, representatives and other people arranging a funeral or memorial;
• from the other Sewardstone company where an enquiry or arrangement involves its services;
• from funeral directors, celebrants and religious officiants;
• from registrars, coroners, medical professionals and public authorities;
• from payment, media, livestreaming and other service providers; and
• automatically when you use our website, subject to your cookie choices.

If you provide information about another living person, please ensure that you are entitled to do so and, where appropriate, direct them to this notice.

4. How responsibility is divided

Sewardstone Burials Limited is responsible for personal information used in connection with:

• burials at Daws Meadow and the Garden of Firdaus;
• burial and ashes plots;
• ashes interment and scattering;
• cemetery deeds and exclusive rights of burial;
• cemetery memorials; and
• related payments and cemetery records.

Sewardstone Park Cemetery and Crematorium Ltd is responsible for personal information used in connection with:

• cremation bookings and administration;
• crematorium services;
• cremation records and certificates;
• chapel services;
• music, visual tributes, livestreams and recordings associated with cremations; and
• related crematorium payments.

Both companies are responsible where information is jointly used for the website, a combined arrangement, shared administration or a general enquiry involving both businesses.

5. Why we use personal information

We use personal information to:

• respond to enquiries and arrange visits;
• provide quotations and take steps before entering a contract;
• administer cremations, burials, ashes, memorials, ceremonies and receptions;
• maintain statutory and operational records;
• issue deeds, certificates, invoices and receipts;
• process payments and administer payment arrangements;
• liaise with funeral directors, officiants, suppliers and public authorities;
• provide music, photographs, tributes, recordings and livestreams;
• accommodate religious, cultural, mobility, dietary and accessibility requirements;
• protect visitors, staff, premises and property;
• investigate complaints, incidents and legal claims;
• meet legal, regulatory, accounting and insurance obligations;
• maintain and improve our website and services; and
• send marketing communications where you have consented or the law otherwise permits.

6. Our lawful bases

We rely on one or more of the following lawful bases:

• Contract: where processing is necessary to enter into or perform a contract with you.
• Legal obligation: where cremation, burial, accounting, regulatory or other law requires us to use or retain information.
• Legitimate interests: where necessary to operate and protect our businesses, administer services, maintain accurate records, prevent fraud, improve services or establish and defend legal claims, provided your rights do not override those interests.
• Consent: for activities requiring a genuine choice, including certain marketing, optional cookies or sensitive information. Consent may be withdrawn at any time.
• Vital interests: in exceptional circumstances involving somebody’s life or physical safety.

Where special-category information about a living person is involved, we also identify an appropriate condition under data-protection law.

7. Sharing information between the companies

The two companies may share personal information where necessary to:

• direct an enquiry to the correct business;
• coordinate arrangements involving burial and cremation;
• operate shared administration, telephone, email and website systems;
• maintain accurate records;
• process complaints or requests;
• prevent fraud and protect the businesses; or
• meet legal and regulatory duties.

Information will not be shared between the companies merely because they are related. Sharing must be necessary, proportionate and connected to a proper purpose.

8. Other organisations with whom we share information

Where necessary, we may share information with:

• funeral directors, celebrants and religious officiants;
• relatives and authorised representatives involved in arrangements;
• cremation and burial authorities, registrars, coroners, healthcare professionals and public bodies;
• payment processors, banks and accounting providers;
• Obitus or another provider used for music, tributes, livestreaming and recordings;
• memorial makers, printers, caterers and other suppliers;
• website hosting, email, IT, security and data-storage providers;
• professional advisers, insurers, auditors and debt-recovery providers;
• police, courts and regulators where disclosure is required or permitted by law; and
• parties and professional advisers involved in a sale or restructuring of either business.

We do not sell personal information.

Service providers handling information on our behalf must protect it and use it only for the agreed purpose.

9. Livestreams, recordings and tributes

Where a service is livestreamed or recorded, the images and voices of officiants, speakers and attendees may be captured. The person arranging the service should make attendees aware of the recording. We will provide reasonable assistance to anyone who does not wish to be filmed.

Recordings and tribute material may be processed by Obitus or another media provider. Access links should be shared only with intended recipients. Online recordings are normally available for 28 days unless another period or a keepsake product has been agreed.

Anyone supplying photographs, music or video is responsible for ensuring that it is provided lawfully and that any necessary permissions have been obtained.

10. International transfers

Some technology and media providers may store or access personal information outside the United Kingdom.

Where this happens, we use an applicable adequacy regulation or another lawful safeguard, such as the UK International Data Transfer Agreement or an approved UK addendum to standard contractual clauses. You may contact us for further information about the safeguards used.

11. How long we keep information

Our usual retention periods are:

• enquiries that do not result in a service: up to 24 months after the last meaningful contact;
• contracts, invoices and payment records: normally seven years after completion of the service or financial relationship;
• cremation and burial registers, deeds and records affecting burial or memorial rights: for the period required by law or necessary to maintain an accurate long-term record, which may be permanent;
• complaints, incidents and legal claims: for as long as necessary to investigate the matter and meet relevant limitation periods;
• online funeral recordings: normally 28 days unless another period or keepsake has been requested;
• CCTV recordings: normally 30 days unless footage is needed to investigate an incident;
• marketing records: until consent is withdrawn or you object, after which minimal suppression information may be retained; and
• website information and cookies: for the periods specified in our Cookie Notice.

Information may be retained for longer where required by law, a regulator, an insurer, litigation or an ongoing dispute.

12. Cookies

Our website uses cookies and similar technologies. Strictly necessary technologies may operate without consent. Analytics, embedded media and other non-essential technologies will only be used after obtaining the consent required by law.

You can accept, reject or change your preferences through our cookie controls. Our Cookie Notice provides details of the individual technologies and their duration.

13. Security

We use appropriate organisational and technical measures to protect personal information against loss, misuse, unauthorised access, alteration and disclosure.

Access is limited to staff and service providers who require the information for legitimate purposes. Please avoid submitting unnecessary sensitive information through ordinary email or a general website enquiry.

14. Your rights

Depending on the circumstances, you may have the right to:

• obtain a copy of your personal information;
• correct inaccurate or incomplete information;
• request erasure;
• restrict the use of information;
• receive certain information in a portable format;
• withdraw consent;
• object to processing; and
• complain about how information is handled.

You have the right to object to processing based on legitimate interests and an absolute right to object to direct marketing.

These rights are subject to legal limitations. For example, we may have to retain statutory cremation or burial records even if erasure is requested.

Requests may be sent to info@spcemetery.com. Please state whether your request concerns burial services, cremation services or both. We may request reasonable proof of identity and do not normally charge a fee.

We do not make decisions about individuals based solely on automated processing that produce legal or similarly significant effects.

15. Marketing

We only send electronic marketing where consent has been given or another lawful permission applies. You may unsubscribe at any time by using the link in a message or contacting us.

Communications necessary to administer an enquiry, booking, payment, deed, memorial or service are not marketing.

16. Data-protection complaints

Please send data-protection complaints to our Privacy Lead:

Email: info@spcemetery.com
Post: Unit 1 Netherhouse Farm, Sewardstone Road, Chingford, London E4 7RJ

Please indicate whether the complaint concerns burial services, cremation services or both.

We will acknowledge a data-protection complaint within 30 days, investigate it without undue delay, keep you appropriately informed and notify you of the outcome.

You may also complain to:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF

Telephone: 0303 123 1113
Website: https://ico.org.uk/make-a-complaint/

We would appreciate the opportunity to address your concern first, but you are not required to contact us before approaching the ICO.

17. Changes to this notice

We may update this notice when our services, suppliers, business arrangements or legal obligations change. The current version will be published on our website with its revision date. Material changes will be brought to the attention of affected individuals where appropriate.