Privacy - Community Wills Sussex

Privacy Policy

Community Wills Sussex takes your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

Community Wills Sussex collects, uses and is responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

Key Terms

Community Wills Sussex collects, uses and is responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).

It could be helpful to start by explaining some key terms used in this policy:

We, us, or	Community Wills Sussex
Personal data	Any information relating to an identified or identifiable individual
Special category personal data	Personal data revealing racial or ethnic origin, political opinions, religious beliefs or trade union membership Generatic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation
Data subject	The individual who the personal data relates to

Your Data

Personal Data We Collect About You

We will collect and use the following personal data about you:

Your name and address
Your contact information, including email address and telephone number
We may also collect your billing information, transaction and payment card information
Information to check and verify your identity and for us to undertake client identity checks on you, e.g., your photographic ID and your proof of address
Information about how you use our website and other systems
Any other information provided on the Community Wills Sussex confidential declaration form

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing our services to you.

How Your Personal Data is Collected

We will collect the majority of this personal data directly from you—in person, by telephone, text or email and/or via our website. We may also collect information from publicly accessible sources such as Companies House or HM Land Registry.

How and Why We Use Your Personal Data

Under data protection law, Community Wills Sussex can only use your personal data if we have a proper reason, e.g.:

Where you have given consent
To comply with our legal and regulatory obligations
For the performance of a contract with you or to take steps at your request before entering into a contract
For our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

We use your personal data for the following reasons:

To perform our contract with you or to take steps at your request before entering into a contract
For our legitimate interest, i.e., to minimise fraud that could be damaging for you and/or us
To comply with our legal and regulatory obligations and gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
To enforce legal rights or defend or undertake legal proceedings
To provide the participating charities with any information regarding any legacies or actions that concern that charity
To complete and record financial transactions which take place between Community Wills Sussex and Britton and Time Limited
To ensure that we are able to manage and track our business to improve our service to our partners
For operational reasons, such as improving efficiency, training and quality control
To prevent unauthorised access and modification to systems and to protect the security of our systems and data sued to provide services
To ensure the confidentiality of commercially sensitive information, i.e., to protect trade secrets and other commercially valuable information and to comply with our legal and regulatory obligations
To update and enhance customer records in order for us to perform our contract with you, comply with our legal and regulatory obligations, and for our legitimate interests
Marketing our services to existing and former clients, third parties who may be interested in our services and to other third parties
Anti money laundering checks, credit reference checks and audits via external providers
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisers acting on their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of insolvency. In such cases information will be anonymised where possible and only shared where strictly necessary

Your information may be included during an analysis of our service, if this survey is published, all information will be anonymised.

Marketing

We will use your personal data so that Community Wills Sussex, our legal partner Britton and Time Limited, and the participating charities may send you updates (by email, text message, telephone or post) with regards to legal services and how your legacy can make a difference and other fundraising events that will be hosted.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

contacting us at [insert contact details for marketing opt-out]; or
using the ‘unsubscribe’ link in our emails.

We may ask you to confirm or update your marketing preferences if you ask Britton and Time to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside the Community Wills Sussex group for marketing purposes.

Your Data

Who We Share Your Personal Data With

We routinely share personal data with our legal partner, Britton and Time Limited and the charities that participate in Community Wills Sussex programmes.

We only allow the participating charities of Community Wills Sussex which you include in your Will to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.

We will not share or sell your personal data with any other third party.

Where Your Personal Data is Held

Your personal data will be kept on file until it is no longer of use to Community Wills Sussex or the executors of your estate. Different retention periods apply for different types of personal data.

Your Rights and Control of Personal Information

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal data
Rectification	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data – in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data in certain circumstances, e.g., if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit data to a third party – in certain situations (see ‘Who we share your personal data with‘)
To object	The right to object: at any time to your personal data being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal data, e.g., processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims.
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consents	If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. You may withdraw consents by contacting us and informing that you wish to withdraw consent. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of those rights, please:

Email, call or write to us—see below: ‘How to contact us’;
Provide enough information to identify yourself (e.g., your full name, address and customer or matter reference number) and any additional identity information we may reasonably request from you; and
Let us know what right you want to exercise and the information to which your request relates

Keeping Your Personal Data Secure

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

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

If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to Complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner in the UK.

The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.

If you wish to make a complaint about any other matter regarding our services, please contact Community Wills Sussex at info@brittontime.com or by calling 0203 007 5500.

Changes to This Privacy Policy

This privacy notice was published on 10/03/2023 and last updated on 10/03/2023.

We may change this privacy notice from time to time, so it is advised that you regularly update yourself with our privacy policy as it appears.

How to Contact Us

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:

Post: 39 Church Road, Hove, East Sussex BN3 2BE
Email: info@brittontime.com
Phone Number: 0203 007 5500

Do you need extra help?

If you need this notice in another format, please contact us.