Privacy Policy

Privacy policy & data subject rights

Identity and contact details

Please click here to find out more about the Your Will Online. Our postal address is 23 Greenacres Woolton Hill, Berks, Newbury, England, RG20 9TA.  You can contact us by email using hello@yourwillonline.com, or by using the contact us form on our web site.  We are registered as a limited company (YOUR WILL ONLINE LTD, registration number 12887607) in England and Wales.

Our designated supervisory authority under the General Data Protection Regulation (GDPR) is the Information Commissioner’s Office (ICO). We are based in the United Kingdom.

To contact the individual in charge of Data Protection in our company please use hello@yourwillonline.com.

What data we collect

Your Will Online processes data on:

  • Customers
  • Agencies
  • Our staff
  • Suppliers

Customers

We process the data that relates to details needed for contact with individuals that create will documents through our service. We use a lawful basis of contract to process this data. Some of the data that the individual enters into the front end is processed by us for the sole purpose of creating a will document for the customer. 

We may also process the data that the customer enters into the front end to enable us to communicate with users of Your Will Online services if they request us to contact them so that we can support them in customising and extending their wills. This is covered by the lawful basis of contract outlined above. 

Agencies

We process information on agencies who could ‘recruit’ individuals to create will documents through our service. We process data on the names and contact details of individuals within the organisations that we target.  We use the lawful basis of legitimate interests to process this data.  We have completed the specification, gate analysis and balancing tests specified under GDPR for this data.  We do not capture special category information on this data.

Staff

We process information on staff in several ways: 

  • We use the lawful basis of contract to process data that is needed to enter into and maintain a contract of employment or other work for Your Will Online, or if individuals are taking steps to enter into a contract (for example for recruitment). This includes keeping track of the amount of time that staff spend on projects or performance evaluation or expenses claims.  We can capture special category information as the processing of this data is necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on the controller or the data subject in connection with employment, social security or social protection.
  • We process information on staff and can pass data on to specific parties because we are legally obliged to. For example, where we pass information to the HMRC on the amount that specified employees are paid.
  • We process information on staff and can pass data on to specific parties because we are acting as an intermediary to a contract between the member of staff and the third party. For example, where we organise pension payments or benefits for staff. We use a lawful basis of contract to process this data. 
  • We process information on staff and their next of kin where it is in Your Will Online’s interest to do so for operational purposes. For example, to keep staff up to date with Your Will Online news, to maintain a list of the staff’s next of kin for communication in the event of an emergency, or to create business cards for staff. We use the lawful basis of legitimate interests to process this data.  We have completed the specification, gate analysis and balancing tests specified under GDPR for this data.  We do not capture special category information on this data.

Suppliers and partners

We process information on suppliers and partners so that we can purchase goods and services from them.  We use a lawful basis of contract to process this data.  We do not capture special category information on this data.

Any recipient or categories of recipients of the personal data

Your Will Online pass data on to other data controllers for the following purposes:

  • For data relating to those applying to be members of staff or for staff who have found other employment after the end of a contract, we share data with third parties to obtain and provide references;
  • As the data controller, we may provide access to data processors that process data on our behalf, who will only process the data according to the written instructions in the Data Processing Agreements in place with them;

We share data with organisations with which we have a legal obligation to share data (for example HMRC).

We share data on staff with organisations where we are acting as an intermediary between the staff and an organisation providing benefits to the staff member (for example pension providers).

Details of transfers to third country and safeguards

We will not transfer data to countries outside the European Economic Area and the UK to destinations that are not considered ‘adequate’ by relevant legislation without the permission of the individuals themselves.

Retention period or criteria used to determine the retention period

We will anonymise data from our CRM system 3 years after the last active contact with an individual.

We will remove data from our email system 6 years after the last contact with an individual. 

We will remove data from the will document creation system 6 years after the documents have been created and downloaded.

We will delete details of staff from our records 6 years after their final date of employment. 

We will retain personal data in our financial systems for the time required by tax legislation. 

If these data retention timescales clash with legal or contractual obligations then these other obligations will override the retention timescales outlined. For example, UK limited companies are required to retain records on tax paid for 6 years. 

All records are disposed of securely when deleted. 

How we look after data

We take reasonable technical and procedural precautions to prevent the loss, misuse or unauthorised alteration of personal data.

We store the personal data that we collect securely.

We do not publish the details of the safeguards we use to protect the personal data that we control as this could reduce the effectiveness of those safeguards.

Cookies

Cookies are text files placed on your computer to collect information about which pages you visit, and how long for. This information is used to track use of the website and to compile statistical reports on website activity.

When you visit our website you will be presented with a choice which will allow you to decide whether cookies are used or not. In a few cases some of our website features may not function if you choose not to allow cookies on our website.

Personal data may be shared with third parties to enable us to conduct web analytics to monitor use of our website. We use Google Analytics however, you can opt out of Google Analytics by using this link: https://tools.google.com/dlpage/gaoptout?hl+en=GB.

Other websites

Our website contains links to other websites. This privacy policy only applies to this website, so when you link to other websites you should read their own privacy policies.

Your rights

Your Will Online recognises the rights of individuals as defined in the General Data Protection Regulation (GDPR).

We will always seek to uphold those rights and the links provided will enable you to communicate with us to exercise those rights, where relevant.

Your Will Online recognises your right to lodge a complaint with a supervisory authority. You can access the ICO’s website from this link.

Version control

Date

 

Alterations

Owner

Initials of reviewer

22 Oct 2020

 

Initial draft of document

Blake Consultants