About this Policy

As a Humanist Celebrant I am committed to putting humanism into practice. Through my ceremonies, I advance free thinking and freedom of choice so everyone can live in a fair and equal society.

When doing this, I process personal data about people who enquire about and/or receive services from me. I am committed to protecting your privacy and take this responsibility very seriously. I therefore take care to safeguard it. This notice outlines what data I collect, how I may use it, how I protect your data and your rights, and how you can exercise those rights.

References to ‘I’ or ‘me’ are to Martha Lawton, Humanists UK accredited celebrant number 449971.

I regularly check this notice to ensure I provide you with the most up-to-date information regarding our data processing activities. I strongly advise you to read this page from time to time to ensure you are happy with any changes that might be made.

This privacy policy was prepared to be as comprehensive as possible, but it does not include an exhaustive list of every aspect our collection and use of personal information. I are happy to provide any further information or explanation about our practices on request.

If you have any questions about this policy, please contact me using the details in the ‘Contact me’ section below.

This privacy policy was last updated on 30 May 2018.

Why I collect your data

I collect personal data for many reasons, including to provide you with services, communicate with you, and send you information you have requested, and administer ceremonies. Depending on how you interact with me, I may process data for the following reasons:

• to provide you with information about ceremonies, Humanists UK, humanism, or Humanists UK-related activities that you have requested
• to communicate with you about my work
• to process personal details required for the administration of ceremonies you have booked or expressed an interest in
• to record and contact you regarding payments you make to me
• for my own internal administrative purposes, and to keep a record of your relationship with me
• to manage your communication preferences
• to conduct surveys, research and gather feedback
• to obtain information to improve my services and families’, and guests’ experiences
• to carry out research to find out more information about my clients’ and prospective clients’ backgrounds and interests
• to comply with applicable laws and regulations, and lawful requests from statutory agencies

Information I collect

I may collect the following personal information:

• your name
• contact details – including your postal address, telephone number(s), and email address(es)
• age
• details of relevant personal circumstances when providing you with ceremonies
• details of family members in order to include these in ceremonies.
• your payment details
• records of your correspondence and engagement with me
• information you may enter via my websites
• photographs, video or audio recordings
• occupation
• biographical information
• IP addresses (for analytics purposes, not stored with your other records)
• other information you share with me
• This information may be collected via:
• any paper forms you complete
• telephone conversations or face-to-face interactions
• digital forms completed via my websites, or online surveys
• publicly available sources
• communication via social media

I sometimes also collect sensitive, personal data about individuals. This includes information about health, religion or belief, sexual orientation, ethnicity, political and philosophical beliefs, and criminal records. I will normally only record this data where I have your explicit consent, unless I am permitted to do so in other circumstances under data protection law.

Using your personal data

Ceremonies and information provision

In the case of details given for the purposes of enquiring about ceremonies or developing ceremony scripts I will keep all your information – including notes, letters and information given to me about you – in a confidential record that is specific to you. I use a password protected note-taking service to support this process. This means that I can keep the information you provide me, so I am able to see the history and relevant details of your interactions with me. This ensures I provide a high quality service and do not require you to repeat details which you have already given. I take information security very seriously. No one is allowed access to my system or files unless they need this to provide a booked ceremony for you, or for one of the other purposes discussed in this notice.

Where you provide information which may be sensitive it will be treated as confidential unless you give me permission to share it. It is stored in secure files and no one is allowed access to our system or files unless they need this to provide a booked ceremony, or for one of the other purposes discussed in this notice.

I may use your data for statistical reports. These statistics will not include any information that could be used to identify any individual.

Direct marketing

I want to keep you up to date with my marketing activity.

I may use a range of marketing activities and channels to contact past and potential clients – including my website, email, direct mail, social media, and telephone.

I will always obtain consent to contact you by email and text message for marketing purposes. I will also obtain consent from all new enquiries to make marketing calls.

I send the following marketing materials:

• updates about my work – including email and paper newsletters and other publications informing you about my work
• details of events, including events held in aid of Humanists UK. Please note that if you sign up to a Humanists UK event they will also send you administrative communications about how you can take part. Humanists UK will also send you a reminder about similar events in future years, in case you want to participate again

I will never share or sell your personal data to a third-party organisation for its marketing, fundraising, or campaigning purposes.

You can withdraw your consent and unsubscribe from or update your marketing preferences at any point using the details in the ‘Contact me’ section below.

Any ‘mass’ electronic communications, such as emails, will have a link to unsubscribe from future electronic communications, so you can manage your own communication preferences.

If you make any changes to your consent, I will update your record as soon as I possibly can. It may take up to 30 days for my systems to update and stop any postal communications from being sent to you. Email communications will be stopped within a week and usually immediately. If you tell me you do not wish to receive marketing communications, you may still receive transactional and service-based communications confirming and servicing other relationships you have with me (as described below).

Where possible, I cleanse and remove out-of-date data. This helps me to improve the delivery rate of my mailings and minimise wasted expenditure.

Administrative communications to clients and potential clients

In addition to the marketing communications that you receive from me, I will also communicate with you by post, telephone, and email in relation to administrative and transactional matters. For example, I may call you after you have completed a booking form to confirm your details.

As mentioned above, I may still need to communicate with you for administrative purposes even where you have opted out of marketing communications from me.

Social media/digital

When someone visits https://martha-lawton.squarespace.com, which is hosted on a third party site, Squarespace.com, I collect standard logging information and details of visitor behaviour – such as which pages are visited, and how long is spent on each one. I do this to find out things such as the number of visitors to the various parts of the site, and how people are using the site. These website statistics and data are collected by Google Analytics and Squarespace Analytics. Google’s system also provides me with non-personally-identifiable ‘Interest’ and ‘Demographics’ data, which is collected using the widely-used Google Advertising Network DoubleClick cookie (see here for more information on this cookie, including how to opt-out). I collect this data so that I can find out the kinds of people visiting my site, and I use this data to help me deliver my messages as effectively as possible. See below for more information about cookies, and here for a way to opt out of Google Analytics on all websites you visit.

When someone visits https://humanist.org.uk/marthalawton/, which is hosted on a third party site, WordPress.com, there is no data automatically collected about that visit by Martha Lawton however WordPress.com may collect data on your during the visit. If you would like to know more about the data collected by WordPress.com, which is not shared with Martha Lawton, please see this notice from Automattic.

I use ‘cookies’ to collect data from your browser when you visit https://martha-lawton.squarespace.com. A cookie is a small text file that is stored on your computer via your web browser. This file allows me to temporarily store information about your website usage. Cookies can also be used by third-parties, and sites such as Facebook can use them to see which websites you have visited. My site has various cookies in place – see the rest of this policy for details of the organisations I work with, and how I ensure that your data is secure. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

If you receive an email and you open it, or don’t open it, or select a link and browse our website, I may collect this information to ensure that the information I send to people is received and relevant.

If you book a ceremony, I will send a link to a booking form which provided by Google Drive. I use this data to ensure that I get the basic details about you, your family, and your ceremony correct. You can see Google’s Privacy Policy here.

Professional contacts

I may collect data about professional contacts and partners with whom I work, or to whom I provide professional services. Personal data collected in this way will be processed in accordance with data protection legislation and this policy.

I may send professional partners information and updates about my work (primarily by email). Such contacts can opt out of receiving this information at any time.

My legal basis for processing personal data

I need a lawful basis to collect and use your personal data under data protection law. The law allows for six ways to process personal data (and additional ways for sensitive personal data). Four of these are relevant to the types of processing that I carry out. This includes information that is processed on the basis of:

• a person’s consent (for example, to send you direct marketing by email)
• a contractual relationship (for example, to provide you with a ceremony)
• processing that is necessary for compliance with a legal obligation

Humanists UK’s legitimate interests (please see below for more information)

Personal data may be legally collected and used if it is necessary for a legitimate interest of the organisation using the data, if its use is fair and does not adversely impact the rights of the individual concerned.

When I use your personal information, I will always consider if it is fair and balanced to do so and if it is within your reasonable expectations. I will balance your rights and my legitimate interests to ensure that I use your personal information in ways that are not unduly intrusive or unfair. My legitimate interests include:

Good governance: including statutory and financial reporting, and any other regulatory compliance purposes

Administration and operational management: including responding to solicited enquires, providing information and services, research, events management, ceremony script writing and delivery

Sending direct marketing by post (and in some cases making marketing calls), sending thank you letters, analysis, targeting and segmentation to develop communication strategies, and maintaining communication suppressions

If you would like more information on my uses of legitimate interests, or to change my use of your personal data in this manner, please get in touch with me using the details in the ‘Contact me’ section below.

Disclosure of your personal data

I will not share any of your personal data with any third party – except where:

• the transfer is to a secure data processor, which carries out data processing operations on my behalf (please see below for more information)
• I am required to do so by law, for example to law enforcement or regulatory bodies where this is required or allowed under the relevant legislation
• it is necessary to protect the vital interests of an individual
• I have obtained your consent

I will never share or sell your personal data to a third-party organisation for marketing, fundraising, or campaigning purposes.

Security of your personal data

I use appropriate technical and organisational measures and precautions to protect your personal data and to prevent the loss, misuse or alteration of your personal data.

Unfortunately, the transmission of information via the internet cannot be guaranteed to be completely secure. Although I will do my best to protect your personal data, I cannot guarantee the security of your data transmitted to my websites. Once I have received your information, I will use strict procedures and security features to try to prevent unauthorised access.

Use of data processors

I may use a third-party supplier to manage mailings for example, for marketing or to conduct research surveys, or storage of your personal information on my behalf. As such I may transfer lists of email or postal addresses to their systems. You can find out more about the suppliers that I use by getting in touch with me using the details in the ‘Contact me’ section below.

I actively screen and monitor these companies and contractors to maximise the protection of your privacy and security. They are only permitted to use the data in accordance with relevant data protection legislation and under strict instructions from me.

Transfers of data outside of the European Economic Area

I endeavour to keep all personal data hosted within the EEA. If it is ever desirable to transfer your data outside of the EEA, I look at this on a case-by-case basis to ensure that robust data-sharing agreements are in place. For example, if the partner hosts its data in the US and is a member of the Privacy Shield scheme. This scheme has been declared by the EU to provide adequate protection for personal data, and as such I am happy to use it.

I use Google products, provided through the Humanists UK business account, which are multi-tenant cloud services, for my internal office use as well as for hosting of forms and other files. This means that internal documents and information generated by me may be stored in cloud services hosted by Google outside of the EEA. Google is a member of the Privacy Shield scheme and Humanists UK have extensive contracts in place with them to safeguard your data. Humanists UK have a business-level account with Google, and personal data is never scanned for advertising purposes.

In cases where I transfer your data outside the EEA, I will take reasonable steps to ensure that the recipient implements appropriate measures to protect your information, for example, by entering into a contract that includes prescribed clauses about the use of data and (if the company is based in the United States, checking that it is accredited under the EU-US Privacy Shield).

Retention of your data

The length of time that your data will be kept may depend on the reasons for which I am processing the data and on the law or regulations that the information falls under, such as financial regulations, Limitations Act, Health and Safety regulation etc., or any contractual obligation I might have, or if I have a business case, such as with research data. For business case data, I will anonymise the data so no individual is identifiable.

Subject to the above, I will typically store data relating to ceremonies, and people to whom I provide services to for seven years after completion of those ceremonies or services. Personal data about ceremony enquiries that do not proceed to bookings are held for 3 months after the initial contact.

Once the retention period has expired, the information will be confidentially disposed of.

If you request to receive no further contact from me, I will keep some basic information about you on my suppression list to avoid sending you unwanted materials in the future.

Your rights

You have many rights under data protection legislation. These include:

Right of Access

You have the right know what information I hold about you and to ask, in writing, to see your records.

I will supply any information you ask for that I hold about you as soon as possible, but this may take up to 30 days. I will not charge you for this other than in exceptional circumstances. If you ask for data to be released to an email or postal address I have not used previously, you may be asked for proof of identity. I need to be sure I am only releasing your personal data to you.

This is called a data subject access request, and can be made by:

• emailing martha.lawton@humanistceremonies.org.uk
• calling 020 3289 0840.

 

Right to be informed

You have the right to be informed how your personal data will be used. This policy, as well as any additional information or notice that is provided to you either at the time you provided your details, or otherwise, is intended to provide you with this information.

Right to withdraw consent

Where I process your data based on your consent (for example, to send you marketing emails), you can withdraw that consent at any time. To do this, or to discuss this right further with me, please contact me using the details in the ‘Contact me’ section below.

Right to object

You also have a right to object to me processing data where I am relying on it being within our legitimate interests to do so (for example, to send you direct marketing by post). To do this, or to discuss this right further with me, please contact me using the details in the ‘Contact me’ section below.

Right to restrict processing

In certain situations, you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.

Right of erasure

In some cases, you have the right to be forgotten (i.e. to have your personal data deleted from our database). Where you have requested that I do not send you marketing materials, I will need to keep some limited information to ensure that you are not contacted in the future.

Right of rectification

If you believe my records are inaccurate, you have the right to ask for those records concerning you to be updated. To update your records, please get in touch with me using the details in the ‘Contact me’ section below.

Right to data portability

Where I am processing your personal data because you have given me your consent to do so, in some circumstances you have the right to request that the data is transferred to an equivalent organisation.

Complaints

If you have any complaints about the way in which I have used your data, please get in touch with me using the details in the ‘Contact me’ section below. I would be happy to help and discuss your concerns.

In addition, you are also entitled to make a complaint to the Information Commissioner’s Office.

Contact Me

If you have any questions about this policy, would like more information, or want to exercise any of the rights set out in section 50 above, you can get in touch with us in the following ways:

martha.lawton@humanistceremonies.org.uk

https://martha-lawton.squarespace.com/get-in-touch/

Tel: 020 3289 0840