Privacy statement
As a Celebrant I will come in contact with clients’ personal information and this policy addresses the steps I am taking to guarantee appropriate data protection and privacy. My guiding principle is that I will collect and keep only personal information which is essential, and only for the necessary time, to fulfil my role as celebrant.
The Information Commissioner’s Office has confirmed (12.3.18) that Legitimate Use is an acceptable basis for storing all data in order to conduct a ceremony, including data belonging to family and friends who are living and are not the customers.
Why I collect data
As a Celebrant, in order to design and write unique and personal ceremonies, I rely on personal information shared from clients, families and friends. The scripts of the ceremonies are reviewed by them, and consent given for the material to be shared as part of the ceremony.
What data I collect
Data I collect include: names, phone numbers, email addresses; people’s personal information i.e., date of birth, death, marriage, schools, employments, and reports of events in the personal, family and professional life which clients are happy to share.
Data is held in the following formats: paper and digital copes of scripts, emails, texts, WhatsApp’s messages, information sheets, questionnaires/ feedback forms (often anonymised) photographs if published on orders of services, and/or shared with the clients’ consent.
What do I do with data
The purpose of keeping these personal data is for arranging and booking appointments, for writing and conducting the ceremonies, and for business record keeping like invoices.
Who do I share data with
Personal data is not shared outside the scope of the ceremony apart from the following exceptions which will always be agreed in advance with the clients
- Images from the ceremonies to be used as part of my business marketing, if, and only if, consent has been given by the client and, when appropriate, by the photographer. Subjects will not be identified by name.
- If requested, and agreed with the client, a script can be shared with other professionals such as funeral directors or wedding planners, for the smooth functioning of the ceremony. However, after the ceremony, I will request to have the script back or for an assurance that it will be destroyed.
- Scripts will be shared with the supervisor at the time of any observations for accreditation, and re-accreditations. However, they will be given back to me afterwards. For peer supervision, scripts will always be shared anonymised.
How I store data
The personal data listed above will be stored on my phone, iPad and personal laptop. I am the only person accessing this equipment, and they are all password secured. Any paper data will be shred after the information has been transferred to a digital file, and paper scripts will be shred after each ceremony, with the exception of the copy or copies given to the clients.
Texts, WhatsApp messages and emails will be deleted after each ceremony. Filed information will continue to be stored in my laptop and its backup system (see below for how long).
How long I keep information for
As explained above, data held on paper and scripts, on texts, WhatsApp and emails will be deleted after each ceremony but electronic information held on my laptop, like booking forms, containing client contact details and invoices will be kept up to 5 years and then deleted.
Any electronic held ceremony script will be completely anonymised within 12 months and kept for training and peer supervision purposes.
Access to the information I hold about you
In the first initial contacts with clients, they will be informed of the content of this policy, and they will be able to see a copy of the policy, if they wish. Having explained how most of the data will be deleted or completely anonymised after the ceremony, if they request that any personal data are completely deleted, I will comply with their request within a week.
Therefore, all personal data will be deleted after 5 years from the date of the ceremony.
Consent
When Consent is given to use or share data for a limited time or withdrawn, I will make sure that the data is no more in use; for example, if it was a photograph on my website this will be deleted within a month.
Reviewing this privacy statement
This statement was written in August, 2023 following guidance from Humanists UK, and will be reviewed once a year.
Lucia Whitney 06/08/2023
Review due on 06/08/2024