William Alty & Sons Ltd

Broomfield Place
Blackburn
BB2 1XF

11 Cann Bridge Street
Higher Walton
Preston
PR5 4DJ

POLICY STATEMENT

William Alty & Sons (Altys’) is committed to the protection of Employee and Customer data. All data within The Company will be compliant with the Data Protection Bill 2018 (DPA) and The UK – General Data Protection Regulations 2021 (UK-GDPR) as upheld in the United Kingdom by the supervisory authority, The Information Commissioners Office (ICO). The Company shall in all respects comply with the obligations contained in the Legislation and any associated Rules and Guidance.

LEGAL/ REGULATORY REFERENCES

• United Kingdom General Data Protection Regulations 2021 (UK-GDPR)
• Data Protection Act 2018 (DPA)

PURPOSE

The purpose of this policy is to:

• Convey Altys’ approach when handling data to ensure compliance, but also to deliver fair customer outcomes;
• Provide an overview of the firm’s approach and processes; and
• Define accountabilities and procedures to be followed.

SCOPE

This document applies to all Altys’ employees (whether full-time, part-time, permanent or temporary), and all parties working for and/or on behalf of Alty’s. This Policy sets out the procedures which must be followed to enable to comply with legal obligations as well as obligations to its clients under current contracts.

RESPONSIBILITIES

has overall responsibility for this Policy and ultimately responsible for ensuring that there is clear local ownership for Data Protection.

Mechanisms must be established and maintained to ensure that:

• All employees, whatever their level of seniority, are aware of their responsibilities in relation to Data Protection;
• This will be primarily achieved by employee induction and on-going training and monitoring; and
• There is an effective, rapid escalation process to report any Data Protection concerns, issues or breaches.

Data Protection Officer (DPO)

The DPO will, in the normal course of business:

• Disseminate relevant Data Protection guidance from external sources;
• Monitoring compliance with this Policy and supporting procedures;
• Monitor training for new entrants; and
• Monitor the provision of refresher training to staff.

Management

Management must ensure that all employees are aware of this policy and that systems and controls put in place are adhered to within their areas.

Employees

Fair treatment of customers is the responsibility of all employees. All Employees must maintain awareness of this Policy by active participation in/completion of relevant training on the subject.

DEFINITIONS

• Personal data – means any data relating to an identified or identifiable natural person (a living individual) from which they can be identified, such as their name, address, contact details, bank account details etc
• Sensitive personal data – Also referred to as “Special Category Data” or “High-Risk Data” is any data consisting of any information relating to a person’s racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a person’s sex life or sexual orientation
• Data subject – is the individual which the data is about, such as a customer or an employee
• Data controller – is the individual or organisation who determines the purposes for which personal data is to be processed.
• Data Processor – is an individual or organisation who processes data on behalf of the data controller.

APPOINTMENT OF A DATA PROTECTION OFFICER (DPO)

Alty’s has appointed a Data Protection Officer (DPO). The role of Data Protection Officer is currently undertaken by Russell Alty.

The role of the DPO is to assist the firm to monitor internal compliance, inform and advise on data protection obligations, provide advice regarding Data Protection Impact Assessments (DPIAs) and act as a contact point for data subjects and the Information Commissioner’s Office (ICO).

PRINCIPLES

Alty’s adheres to the 7 principles of the DPA:

1. Lawfulness, fairness and transparency;
2. Purpose Limitation;
3. Data Minimisation;
4. Accuracy;
5. Storage Limitation;
6. Integrity and Confidentiality (security);
7. Accountability.

RIGHTS OF DATA SUBJECTS

The UK-GDPR sets out the following rights applicable to data subjects (please refer to the parts of this policy indicated for further details):

1. The right to be informed;
2. The right to rectification;
3. The right to erasure (also known as the ‘right to be forgotten’);
4. The right to restrict processing;
5. The right to data portability;
6. The right to object; and
7. Rights with respect to automated decision-making and profiling.

LAWFUL, FAIR AND TRANSPARENT DATA PROCESSING

The UK-GDPR seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. The UK-GDPR states that processing of personal data shall be lawful if at least one of the following applies:

1. The data subject has given consent to the processing of their personal data for one or more specific purposes;
2. The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract with them;
3. The processing is necessary for compliance with a legal obligation to which the data controller is subject;
4. The processing is necessary to protect the vital interests ofthe data subject or of another natural person;
5. The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller; or
6. The processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

If the personal data in question is “special category data” (also known as “sensitive personal data”), for example, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation, at least one of the following conditions must be met:

1. The data subject has given their explicit consent to the processing of such data for one or more specified purposes.
2. The processing is necessary for the purpose of carrying out the obligations and exercising specific rights of the data controller or of the data subject in the field of employment, social security, and social protection law.
3. The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent;
4. The data controller is a foundation, association, or other non-profit bodies with a political, philosophical, religious, or trade union aim, and the processing is carried out in the course of its legitimate activities, provided that the processing relates solely to the members or former members of that body or to persons who have regular contact with it in connection with its purposes and that the personal data is not disclosed outside the body without the consent of the data subjects;
5. The processing relates to personal data which is clearly made public by the data subject;
6. The processing is necessary for the conduct of legal claims or whenever courts are acting in their judicial capacity;
7. The processing is necessary for substantial public interest reasons, which shall be proportionate to the aim pursued, shall respect the essence of the right to data protection, and shall provide for suitable and specific measures to safeguard the fundamental rights and interests of the data subject;
8. The processing is necessary for the purposes of preventative or occupational medicine, for the assessment of the working capacity of an employee, for medical diagnosis, for the provision of health or social care or treatment, or the management of health or social care systems orservices on the basis of UK law or pursuant to a contract with a health professional, subject to the conditions and safeguards referred to in Article 9(3) of the UK-GDPR
9. The processing is necessary for public interest reasons in the area of public health, for example, protecting against serious cross-border threats to health or ensuring high standards of quality and safety of health care and of medicinal products or medical devices, on the basis of UK law which provides for suitable and specific measures to safeguard the rights and freedoms of the data subject (in particular, professional secrecy); or
10. The processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) of the UK-GDPR based on UK law which shall be proportionate to the aim pursued, respect the essence of the right to data protection, and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the data subject.

SPECIFIED, EXPLICIT AND LEGITIMATE PURPOSES

1. The Company collects and processes the personal data set out in this Policy. This includes:
   1.1. Personal data collected directly from data subjects; and
   1.2. Personal data obtained from third parties.
2. The Company only collects, processes, and holds personal data for the specific purposes
   set out in this Policy (or for other purposes expressly permitted by the UK-GDPR).
3. Data subjects are kept informed at all times of the purpose or purposes for which the
   Company uses their personal data.

ADEQUATE, RELEVANT AND LIMITED DATA PROCESSING

The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as set out in this policy.

ACCURACY OF DATA AND KEEPING DATA UP-TO-DATE

The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out below.

The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

DATA RETENTION

When any data, and in particular personal data, is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it must be securely deleted and/or disposed of using the methods described in our Information Security Policy.

All data is retained for the legally defined periods as per our privacy notices. Once retention is no longer required the deletion of said data will be handled in line with the Information Security Policy.

SECURE PROCESSING

The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in this Policy.

ACCOUNTABILITY AND RECORD KEEPING

The DPO shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other data protection-related policies, and with the UK-GDPR and other applicable data protection legislation. The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:

1. The name and details of the Company, its DPO, and any applicable third-party data
   processors;
2. The purposes for which the Company collects holds, and processes personal data;
3. Details of the categories of personal data collected, held and processed by the Company, and the categories of data subject to which that personal data relates;
4. Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
5. Details of how long personal data will be retained by the Company;
6. Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

KEEPING DATA SUBJECTS INFORMED

The Company shall provide the information set out in this policy to every data subject. Where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection. This information is detailed in the firm’s Customer and Employee
Privacy Notices.

DATA SUBJECT ACCESS REQUESTS

Data subjects may make subject access requests (“DSARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.

Data subjects wishing to make a SAR may do so in writing. SARs should be addressed to the Company’s DPO.

DPO: Russell Alty
Email: admin@altysfunerals.co.uk
Address: 2 Gurney Street, Blackburn BB2 1XF

Responses to SARs shall normally be made within one month of receipt, however, this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.

The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

RECTIFICATION OF PERSONAL DATA

Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.

The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

ERASURE OF PERSONAL DATA

Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

1. It is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for which it was originally collected or processed;
2. The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
3. The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so);
4. The personal data has been processed unlawfully;
5. The personal data needs to be erased in order for the Company to comply with a particular legal obligation.

Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

RESTRICTION OF PERSONAL DATA PROCESSING

Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any)that is necessary to ensure that the personal data in question is not processed further.

In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

OBJECTIONS TO PERSONAL DATA PROCESSING

Data subjects have the right to object to the Company processing their personal data based on legitimate interests and direct marketing (including profiling).

Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.

Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing immediately.

AUTOMATED DECISION-MAKING

The Company doesn’t use personal data in automated decision-making processes.

PROFILING

The Company doesn’t use personal data for profiling purposes.

DATA SECURITY – TRANSFERRING PERSONAL DATA & COMMUNICATIONS

The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

1. Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances.
2. All personal data to be transferred physically, whether in hardcopy from or on removable electronic media shall be transferred in a suitably secure method.

DATA SECURITY- STORAGE

The Company shall ensure that the following measures are taken with respect to the storage of personal data:

1. All electronic copies of personal data should be stored securely.
2. All hard copies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar.

DATA SECURITY- DISPOSAL

When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of.

DATA SECURITY – USE OF PERSONAL DATA

The Company shall ensure that the following measures are taken with respect to the use of personal data:

1. No personal data may be shared informally and if a member of staff working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from a senior manager.
2. Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised staff at any time.
3. If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it.
4. Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the person responsible for marketing to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the MPS or TPS.

DATA SECURITY – IT SECURITY

The Company shall ensure that the following measures are taken with respect to IT and information security:

1. All passwords used to protect personal data should be appropriately robust and follow the advice of the current IT supplier.
2. Under no circumstances should any passwords be written down or shared between staff, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method.
3. All software (including, but not limited to, applications and operating systems) shall be kept up-to-date.
4. No software may be installed on any Company-owned computer or device without prior approval.

ORGANISATIONAL MEASURES

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data. Staff is defined as in the “Scope”:

1. All staff, shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the UK-GDPR and under this Policy, and shall be provided with a copy of this Policy.
2. Access to personal data will be restricted to those staff, to those that need access.
3. All staff handling personal data will be appropriately trained to do so.
4. All staff will be appropriately supervised.
5. All staff shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise.
6. Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed.
7. All personal data held by the Company shall be reviewed periodically.
8. The performance of those staff handling personal data shall be regularly evaluated and reviewed.
9. All staff handling personal data will be bound to do so in accordance with the principles of the UK-GDPR and this Policy by contract.

IDENTITY VERIFICATION

Appropriate and robust measures are in place to verify the identity of new customers in order to comply with both DPA and AML/ Financial Crime requirements.

For existing customers, the below measures are in place to verify identity and protect disclosure of personal information:

Inbound Calls – On all inbound calls, prior to disclosing any information the following (where available) must always be confirmed correctly by the customer –

• Customers full name
• First line of address
• Postcode

Outbound Calls – On all outbound calls, prior to disclosing any information the following (where available) must always be confirmed correctly by the customer –

• Confirm you are speaking to the correct person by asking to speak to the customer using their full name
• First line of address
• Postcode

TRANSFERRING PERSONAL DATA TO A COUNTRY OUTSIDE THE UK

The Company does not transfer (‘transfer’ includes making available remotely) peoples personal data to countries outside of the UK.

DATA BREACH NOTIFICATION

All personal data breaches must be reported immediately to the Company’s DPO. If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the DPO must ensure that the ICO is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.

In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described) to the rights and freedoms of data subjects, the DPO must ensure that all affected data subjects are informed of the breach directly and without undue delay.

Data breach notifications shall include the following information:

1. The categories and approximate number of data subjects concerned.
2. The categories and approximate number of personal data records concerned.
3. The name and contact details of the Company’s DPO (or another contact point where more information can be obtained).
4. The likely consequences of the breach.
5. Details of the measures taken or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

MONITORING

The DPO is responsible for reviewing and auditing the procedures set out in this Policy and Periodic audits or reviews will be conducted in order to verify that the policy is appropriately implemented. Non-compliance with this policy may result in disciplinary and/or criminal proceedings against an individual, which may include their managers.