This Privacy notice sets out details of the information we collect about you, how we may use it, how we ensure it’s kept secure, who we share it with, and what rights you may have in respect of that information.
We mainly use your personal information to provide our services to you, to meet our legal obligations, and to help improve our interests.
- We only want to hold as much personal information as we need to do the above.
- We want our personal information relationship to be reciprocal where we both benefit, not an exploitative one.
- Where we share your data, we only do so with organisations who have a right to see it and who will use it fairly.
- We take security seriously.
- You can contact us at any time about anything relating to this notice or the information we hold about you.
Who we are
The Co-operative Group Limited (“The Co-op”) has a family of businesses including Food, Insurance, Legal Services and Funeralcare.
In relation to Funeralcare, we now have two businesses. Funeral Services Limited (FSL) offers funeral services, whilst Co-op Funeral Plans Limited (CFPL) provides pre-paid funeral plans. This Privacy Notice applies to both FSL and CFPL.
Why we ask for your personal information
Where we need your information to do what we’ve promised
Our main use of your information is where it’s necessary to supply you with our products and services, or where it's necessary as part of the management of our Membership programme.
For example, we’d need your name, address and payment details when you purchase a funeral, or funeral plan so we can:
- provide the product you’ve requested
- communicate with you about the product and service you’ve enquired about or purchased
- collect your payment
Where we need your personal information to help us get better at everything we do
These are things we consider to be our legitimate interests, some of which will depend on the product or service you’ve purchased.
- Developing an understanding of the activities, preferences, and requirements of our customers. For example, we’ll track activity on our website and App, sometimes using cookies to understand the pages people visit so we can offer the best layout of our site. Sometimes we’ll contact you to seek feedback on a product or service you’ve requested.
- For statistical analysis to improve existing products and services and develop new products and services.
- To better understand the common and more general needs of our customers. This helps us make sure we offer the right products and services and generally meet the needs of our customers.
- To give you a better and more personalised experience (this is sometimes referred to as 'profiling’). For example when we look at how people interact with us, we might use this data to give you personalised offers based on your purchases and enquiries. Sometimes, we'll probably make some wrong assumptions about you and we're really sorry about that.
- Communicating with you about the products and services we’re providing to you. We may use your personal details to send you things we think you need to know about and things we are obliged to send you legally. We broadly term these "service" emails. For example we send customers updates about things like changes to the products and services they’ve bought. We may also send individual customers timely information we think they need to help them, for example when they have unsuccessfully attempted to sign-in to their account.
- Promoting, marketing and advertising our products and services. For example, we might look at a combination of your personal information to try and determine where we might be best placing a television or press advert.
- To obtain feedback on our performance, to assess customer service and satisfaction and to improve overall operations. This might include sending emails inviting you to provide feedback, sometimes using a partner to collate this feedback.
- Running checks for identification and creditworthiness against databases such as, the electoral register and other databases that contain publicly available information about County Court judgments, bankruptcy and repossessions.
- To contact your Nominated Representative about in line with your instructions, or alternatively to try and make contact with you in the event you appear to have moved without informing us.
- Where you make a complaint, to handle that complaint and ensure that we are in the best position to address the issues you raise.
Other ways we might use your personal information
We may also need to process your personal data from time to time where necessary for:
- preventing and detecting crime or anti-social behaviour. For example, we'll use CCTV in some of our buildings
- dealing with any legal claims
If we're using your personal information in the above ways, we really understand that your data has a value and therefore we try to use it for everyone’s benefit. We also try really hard to ensure there will be little or no negative impact on you. This is part of our commitment to ensure that we consider all privacy concerns at the earliest possible opportunity.
Our legal basis for using your information
We will only use your personal information where:
We have your consent
For example we might rely on your consent in order to send you direct marketing communications. Where we do, you can withdraw your consent at any time, most typically by "unsubscribing" from our emails, or alternatively by contacting us at the details given below.
It's necessary for the purposes of our legitimate interests
These interests are set out above (see 'Where we need your personal information to help us get better at everything we do'), and we will only use such data where those interests are not outweighed by your own interests or fundamental rights and freedoms.
It's necessary for the performance of a contract
Either when we're in a contract with you or to take steps as requested by you prior to entering into a contract.
It's necessary for compliance with a legal obligation we have to protect your vital interests
For example if we needed to share your information with a health professional because you’d fallen ill.
Please note that where we require you to provide certain information in order to perform our contractual obligations and you decline to do so, this may delay our performance of the contract or prevent us from honouring our contractual obligations.
The types of information we hold about you
Almost all of the information we have is the information you've given to us. That might be when you request a product, service, offers or news from us via our website, emails, telephone conversations, and written and verbal communication.
Obviously the types of information you give us will vary depending on the service you’ve requested but typically could include:
- name, address, and contact details
- details of products and services you've bought from us
- details of your interactions with us through our funeral homes, contact centres or online
- payment details
- call recordings
- information about how you interact with our communications
- visual images, personal appearance and behaviour (usually obtained from CCTV images)
As well as obtaining information from you, we may also collect it from:
- someone else acting on your behalf who gives us the information directly
- other Co-op Group companies such as Co-op Insurance, Funeralcare, Food and Legal Services where there is a lawful basis to share this data, for example to administer our Membership scheme
- publicly available sources such as social media and the electoral register
- fraud prevention and detection agencies, organisations and databases
- government and law enforcement agencies and regulators
It's also possible we might process other types of information that might be considered even more private, such as information relating to health or religious beliefs to provide the services you request. These are considered "special categories" of personal information and we're obliged to handle this information even more thoughtfully.
See a full list of special category information on the ICO's website.
Sharing your personal information
When we share your information, we only do so in accordance with our legal, data protection and privacy obligations.
Your information may be disclosed to the following:
- Service providers. We use a number of other organisations who carry out work on our behalf to help us provide our products and services. We ensure any third parties we may share your data with have at least the same privacy and security standards as ourselves and will only use your information for the specific reasons we ask them to. This may also include partners who provide additional services such as florists and other funeral items.
- Companies, brands and businesses within the Co-operative Group. We may also share information throughout the Co-op for the reasons outlined such as core administration and activities that have been identified as being within our legitimate interests. For example, we'll share information from our Co-op Funeralcare businesses with other businesses within the Co-op to ensure you receive your Membership rewards or to help provide our Bereavement Notification Service. We may also share information where we decide to restructure part of our business and, for example, we transfer responsibility for the services we provide to you to another business within the Co-op Group
- Credit reference agencies. For example they may supply anti-fraud and credit-insight information to us.
- Social media companies and our advertising partners. For example we might match your email address with Facebook and Twitter to enable us to run promotions on their platforms. If you don’t want your data transferred to the Social Media sites you already use, please notify us at the contact details below.
- Our regulators. For example, we may need to share your information with the Information Commissioner’s Office or the Financial Ombudsmen Service if we receive a complaint.
- Our professional advisors. For example we may need to share information with our lawyers or auditors when they need it to give us their professional advice.
- Public authorities, agencies and other government bodies. For example we might need to provide your information to the police.
- Potential corporate buyers. Where we consider selling any of our Co-op Group businesses or substantially all of its assets to a third party outside the Co-op group. We may need to disclose documentation and other information that may include your personal information.
How long we keep personal information
We only keep your information for as long as it's needed for each of the activities we’ve identified in this Notice, as well as for as long as required in connection with our legal or regulatory obligations.
As you might expect, that will vary but we're happy to share more specific retention schedules if you wish to contact us on the contact details below.
Transferring your information outside the European Economic Area (EEA)
We may need to transfer your personal information outside of the EEA in order to provide you with the services and products you require or as necessary for our business. This will most likely occur when our third-party providers are based outside the EEA. Some of these countries may not have laws that protect privacy rights as extensively as in the EEA.
If we do transfer your personal information to other jurisdictions, we will take proper steps to ensure that your information is as equally protected as in the UK, such as entering into "standard data protection clauses" with the recipient. These are clauses that have been approved by the European Commission for such transfers.
Your rights about how your personal information is handled
Data protection laws provide you with a number of rights as set out below.
Right to access your personal data
You may request confirmation that we hold personal data about you, as well as access to a copy of any such data.
Right to rectification
You may ask us to rectify any inaccurate information we hold about you.
Right to erasure
You may ask us to delete your personal information.
Right to restriction
You may ask us to restrict the processing of your personal information in certain circumstances.
Right to portability
You may request the receipt or transfer to another organisation in a structured, commonly used and machine-readable form, the personal data that you have provided to us.
Right to object
You may object to our processing of your personal information in certain circumstances.
Right to withdraw consent
Where our processing of your personal information is based on your consent, you may withdraw this consent at any time, although this won’t affect the lawfulness of any prior processing where we relied on your consent.
Right to make a complaint
You may make a complaint about our processing of your personal data by contacting us via the contact details provided in this Notice. While we hope that we would be able to address any issues you have in respect of this processing, you may also make a complaint to the UK’s data protection regulation - visit the Information Commissioner’s Office.
If you would like to exercise any of your rights, please contact us using the contact details set out below.
Sometimes we use your personal information in automated processes to make decisions about you, or to create a profile of you. If you are a Member, we may also generate a profile ‘score’ for you, which is designed to provide benefits such as discounts on Co-op products and services. Our use of automated decision making, for example in respect of our insurance products, is to help ensure that decisions are made accurately, fairly and efficiently.
How you can contact us
To find out what personal information we hold about you, print a subject access request form, fill it in and send it by post to:
Data Protection Team, 9th Floor, 1 Angel Square, Manchester M60 0AG
For other enquiries or to get a subject access request form by post, write to us at the address above or call 0800 0686 727.
The information we hold about you will depend on how you shop and interact with us, so the more information you can give about what it is you want you see, the quicker and more specific our response can be.
You also have the right to request we correct any inaccurate information we hold, as well as the right to object to profiling and the right to ask us to delete your information.
If you have any questions, concerns or objections about how we use your personal information please contact us using the details above.
If you have any concerns or complaints about how we handle your information you can complain to the Information Commissioner's Office, although we'd really like the chance to try and help with any issues first.
Changes to this Privacy notice
If we make significant changes to the notice we’ll contact you directly to let you know.
We encourage you to check back regularly.