Silver Clouds Funeral Plans
YOUR RIGHTS, YOUR INFORMATION AND HOW WE
Silver Clouds Later Life Planning Limited (“Silver Clouds”) are
committed to protecting your personal information. Our Privacy
Policy contains important information about what personal details
we collect, what we do with that information, who we may share it
with and why and your choices and rights when it comes to the
personal information you have given us. We may need to make
where your personal data will be processed, any changes will be
18 May 2018.
HOW TO CONTACT US
information we collect or use about you, please contact the
Data Protection Officer, Silver Clouds Later Life Planning, 16-
20 South Street, Hythe, Southampton SO45 6EB
INFORMATION WE COLLECT AND USE INCLUDES
• Information about who you are e.g. your name, date of
birth and contact details.
• Information connected to your products or service with
us e.g. your name and address details.
• Information about your contact with us e.g. meetings,
phone calls, emails and letters.
• Information classified as ‘sensitive’ personal information
e.g. relating to your health, marital or civil partnership
status, race, ethnicity and/or religious beliefs will only be
collected and used where it is needed to provide the
product or service you have requested or to comply with
our legal obligations.
• Information you may provide to us about other people
e.g. joint applicants, trustees, personal representatives,
next of kin or beneficiaries.
WHERE WE COLLECT YOUR INFORMATION
• an application form or contract for a product or service.
• website enquiry form.
• telephone conversations with us.
• emails or letters you send to us.
• meetings with one of our representatives.
We may also collect personal information on you from places such
as business directories and other commercially or publicly
available sources e.g. to check or improve the information we hold
(like your address) or to give better contact information if we are
unable to contact you directly.
WHAT WE COLLECT AND USE YOUR INFORMATION
We take your privacy seriously and we will only ever collect and
use information which is personal to you where it is necessary, fair
and lawful to do so. We will collect and use your information only
• you have given us your permission (consent) to send you
information about products and services offered by us
which we believe may be of interest and benefit to you.
• it is necessary to provide the product or service you have
requested e.g. for the provision of your funeral plan
• it is necessary for us to meet our legal or regulatory
obligations e.g. to tell you about changes to our terms
and conditions or for the detection and prevention of
• it is in the legitimate interests of Silver Clouds to deliver
appropriate information and guidance so you are aware
of the options that will help you get the best outcome
from your products or services or future products or
services. We may also need to process your information
to better understand you and your needs so we can send
you more relevant communications about the products
and services you have with us.
• it is in the legitimate interests of a third party e.g. sharing
information with your nominated funeral director.
If you do not wish us to collect and use your personal information
in these ways, it may mean that we will be unable to provide you
with our products or services.
WHO WE MAY SHARE YOUR INFORMATION WITH
We may share your information with third parties for the reasons
outlined in 'What we collect and use your information for'
These third parties include:
• Your nominated professional advisers, personal
representatives, next of kin, custodians, attorneys and/or
• Companies we have chosen to support us in the delivery
of the products and services we offer to you and other
clients e.g. agents, consultants, funeral directors,
crematoriums, burial plot providers, places of worship,
florists, solicitors, custodians, investment managers,
trustees, accountants, auditors, compliance firms,
technology companies, payment service providers,
couriers, or companies who help us in our contact with
you, for example an internet service provider or cloud
• Marketing analytics, business development and customer
service companies that assist us with marketing analysis
and customer surveys.
• Our regulators, supervisory authority, quality assurance
companies and trade bodies including the Information
Commissioner’s Office for the UK (ICO).
• Law enforcement or other authorities, credit and identity
check agencies for the prevention and detection of crime.
WHERE YOUR INFORMATION IS PROCESSED
Your information is processed in the UK and the European
Economic Area (EEA). However, some of your information may
be processed by us or the third parties we work with outside of the
EEA. Where your information is being processed outside of the
EEA, we take additional steps to ensure that your information is
protected to at least an equivalent level as would be applied by UK
/ EEA data privacy laws e.g. we will put in place legal agreements
with our third-party suppliers and do regular checks to ensure they
meet these obligations.
HOW WE PROTECT YOUR INFORMATION
We take information and system security very seriously and we
strive to comply with our obligations at all times. Any personal
information which is collected, recorded or used in any way,
whether on paper, online or any other media, will have appropriate
safeguards applied in line with our data protection obligations.
Your information is protected by controls designed to minimise
loss or damage through accident, negligence or deliberate actions.
Our employees also protect sensitive or confidential information
when storing or transmitting information electronically. Our
security controls are aligned to good practice standards providing a
controlled environment that effectively manages risks to the
confidentiality, integrity and availability of your information.
HOW LONG WE KEEP YOUR INFORMATION
We will keep your personal information only where it is necessary
to provide you with our products or services while you are a client.
We may also keep your information after this period but only
where required to meet our legal or regulatory obligations. The
length of time we keep your information for these purposes will
vary depending on the obligations we need to meet.
YOUR INDIVIDUAL RIGHTS
You have several rights in relation to how Silver Clouds uses your
information. They are:
RIGHT TO BE INFORMED
You have a right to receive clear and easy to understand
information on what personal information we have, why and who
RIGHT OF ACCESS
You have the right of access to your personal information. If you
wish to receive a copy of the personal information we hold on you,
you may make a data subject access request (DSAR).
RIGHT TO REQUEST THAT YOUR PERSONAL
INFORMATION BE RECTIFIED
If your personal information is inaccurate or incomplete, you can
request that it is corrected.
RIGHT TO REQUEST ERASURE
You can ask for your information to be deleted or removed if there
is no compelling reason for Reap to continue to have it.
RIGHT TO RESTRICT PROCESSING
You can ask that we block or suppress the processing of your
personal information for certain reasons. This means that we are
still permitted to keep your information but only to ensure we don’t
use it in the future for those reasons you have restricted.
RIGHT TO DATA PORTABILITY
You can ask for a copy of your personal information for your own
purposes to use across different services. In certain circumstances,
you may move, copy or transfer the personal information we hold
to another company in a safe and secure way.
RIGHT TO OBJECT
You can object to us processing your personal information where it
is based on our legitimate interests or for direct marketing.
HOW TO MAKE A COMPLAINT
We will always strive to collect, use and safeguard your personal
information in line with data protection laws. If you do not believe
please contact us and we will do our utmost to make things right. If
you are still unhappy, you can complain to our supervisory
authority. Their contact details are:
ICO helpline: 0303 123 1113
ICO website: www.ico.org.uk
ICO address: Information Commissioner’s Office, Wycliffe House,
Water Lane, Wilmslow SK9 5AF