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Privacy Notice

Who we are

We are Life Ledger. We provide a simple service to allow individuals to send notifications to companies the deceased had accounts with. We also provide a secure online life planning account service to hold an individual’s estate details, their will, any personal instructions and details of friends, family, solicitors, and executors ready for end of life (known as ‘Register a life’ or ‘End-of-life planning tool’).

 

Contents

  1. The terms we use
  2. Creating an account
  3. Identity check
  4. Registering a death
    • Information provided by funeral directors
    • Companies who advertise with us
  5. Registering a life
    • Registering your own life
    • Registering someone else’s life
  6. Adding companies and sending notifications
    • Sharing information with service providers
    • Messaging function to contact us and service providers
  7. Customer support
  8. Open banking: Life Ledger Discovery
  9. Retention and deleting your account or information
  10. Marketing
  11. Data sharing
  12. Data location 
  13. Analytics
  14. Your privacy rights
  15. GDPR lawful bases
  16. Contact us
  17. Information for service providers

 

1. The terms we use 

Account owner: this is the person who sets up a Life Ledger account. The account owner may be:

  • sending notifications;
  • acting on behalf of a client to send notifications; or
  • storing their own or someone else’s life information for the future. 

The account owner is also responsible for paying any subscription fee (if applicable). 

There may be more than one person involved in a registered death, for example, the person who starts the process to notify companies may add a solicitor and the deceased’s partner. Or a solicitor handling the notifications may add the partner of the deceased and the will executor. The individuals who have been added can then set up their own account to access the details of the registered death. They then become an account owner for their own account. 

Service provider: any business or organisation notified of a death through the Life Ledger service.

Registered death: this is the detail and activity relating to a deceased individual.

Registered death executor: this is the person who is the executor for the estate of the deceased.

Registered death administrator: this is the person who is administering the estate of the deceased in the situation where there is no will.

Registered death partner: this is the partner of the person whose death is being notified.

Registered death collaborator: this is a person who is neither the partner nor the executor / administrator, but who is or will be involved in some way with a notification (for example, a solicitor).

Registered life: this is the estate details of a living individual.

Registered life executor: this is the person who is the executor for the estate of the person whose estate details are being stored.

Registered life partner: this is the partner of the person whose estate details are being stored.

Registered life collaborator: this is a person who is neither the partner nor the executor, but who is or will be involved in some way with the life registration (for example, a sibling or someone added to inform them of the life registration so they can take action when the individual dies).

2. Creating an account

To set up your account we will need the following information.

  • Title and name
  • Contact details: e-mail, phone, address. 
  • Date of birth
  • Payment card details for the subscription fee (if applicable)
  • Login details: email and password you create (we do not have access to your password)

3. Identity check

We need to make sure that anyone sending notifications is who they say they are. The service providers receiving the notifications need to know they can trust them. Before you can send any notifications, you will need to pass an ID check.

We do this by checking your name, address and date of birth against credit reference agency records. You will see information about which credit reference agency we will use when you go through the check. The check is recorded on your credit file as an identity check and is a ‘soft search’ which means it does not affect your credit score and is not seen by organisations checking your credit file. 

When you send notifications we will tell the service providers that you passed the ID check. We will keep your identity check information for as long as it is needed. If you add additional accounts, we won’t need to redo your ID check.

If the credit reference agency check fails, we ask you to upload a copy of a government-issued ID document. We check the details you provided on registering against the ID document and the information the credit reference agency provided, if they held any information about you. The initial check can fail due to typing errors, use of a previous or abbreviated name, a change of address, an overseas address, or if you don’t have any or enough credit history for the credit reference agency to check your details against.

We store your ID document copy securely on our servers, and provide it with the notification to any service provider who requires it to manage the notification. Some service providers specifically request it because their own processes require them to carry out their own identity checks. You can optionally add an ID document at any time. If you have not added one, and you want to send a notification to a service provider who requires it, we will ask you to upload it.  

Please note that we are in the process of updating our back-end systems so until this is complete you may be asked for an ID document as part of the credit reference agency check process.

4. Registering a death

You must have the authority to send notifications on behalf of the deceased. 

You will need to provide the following information about the deceased, as this is the information service providers usually need when they process notifications.  

  • Title and name
  • Current address and any previous addresses if they were at the current address for less than 3 years.
  • The ownership status of the property and if it is currently empty or occupied. 
  • Date of birth
  • Date of death
  • Your relationship to the deceased
  • Funeral date (optional – this is so you are not contacted on this date)
  • If the deceased has a partner / spouse and, if so, the partner’s name, email and phone number. If you are the partner we will pre fill your details from the ones you have already provided. If the deceased has a living partner, service providers will need their name and contact details to transfer the account if needed and to contact them about the transfer.
  • Death certificate: some service providers need a copy of the certificate; some only need certain details from it.
  • If the deceased has a will and, if so, the name, email and phone number of any executor(s) and whether a grant of probate has been issued. You can also upload a copy of the will and grant of probate. 
  • If there is no will, the details of the administrator and whether letters of administration have been issued. You can also upload the letter of administration. 
  • The name and contact details of any legal representative (optional).

We will send an email to anyone you add to inform them that you have added them. They will then be able to set up a Life Ledger account and see the registered death details.

You can then start adding the companies the deceased had accounts with, and sending the notifications. See ‘Adding companies and sending notifications’ for more information. 

Information provided by funeral directors

Some funeral directors work directly with us, so if you have agreed to use our service while talking to them, they will automatically send us some of the information listed above about you and the deceased. This means you don’t have to repeat it all when you start to use our service. We will send you an email if you come to us through this route.

Details sent to us:

Bereaved: name, address, contact details, date of birth, relationship to deceased.

Deceased: name, address, date of birth, date of death, funeral date (if relevant and known), surviving partner details, executor details.

Companies who advertise with us

When you provide the details of the deceased, at certain points you may see information on companies offering services that may be relevant and useful to you. For example, if you do not have legal representation we show you partner law firms in the same postcode area as the deceased’s address. We will show their name and contact details, including a link to their website that you can click through to if you want. We do not track any clicked links but the company may have website tracking to know you came to them from the Life Ledger website. 

We also have a probate partner – Sail Probate – who you can book a phone appointment with from within our platform. To do this you will need to share your name and phone number with Sail Probate. You may have the option to share the following information to help them prepare for the call.

  • The full name of the deceased.
  • Your relationship to the deceased (child, partner and so on).
  • Your position in terms of administering the estate (executor, administrator or neither).
  • Whether the estate includes any property.  

Sail Probate are responsible for the information you provide after you have provided it. We encourage you to read their privacy notice. They will share with us some information about how many people who booked an appointment have bought their services, and they pay us a commission.

5. Registering a life

You can register your own or someone else’s life. We ask if the person whose life is being registered is terminally ill (they have a terminal diagnosis or are in end of life care). If either of these is the case at the time of registration then we waive any fees for the service. This information is optional and is not used for any other purpose.

After the death of the person whose life is registered, whoever is handling the notifications to companies will need to add further information, such as the date of death, and a copy of documents such as the death certificate and a will.

Registering your own life

We will prefill your basic contact details and date of birth from your account setup information.

You will then need to add the following information.

  • Your previous addresses if you have not lived at your current address for 3 years or more.
  • The ownership status of the property. Utilities and insurance providers often request this information to process notifications.
  • If you have a partner and, if so, their name, email and phone number.
  • If you have a will and, if so, the name, email and phone number of any executor(s). You can choose if the executor has full access or read-only access. You can also upload a copy of your will and indicate who you want it to be visible to. 
  • You can also upload any funeral plan, insurance policy or other relevant documents and choose who you want them to be visible to.
  • You can add the contact details of any other person you want to tell about the life registration, so that they can take action to notify companies after you die.

We will send an email to anyone you add to inform them that you have added them. They will then be able to set up a Life Ledger account and see the life registration details, details of others you have added, and any documents (in line with the document access permissions you have set).

You can then start adding the companies you have accounts with. See ‘Adding companies’ for more information. 

Registering someone else’s life

If you are the next of kin, or a will executor for a relative, you may want to register their life in advance, so you have all the details you need to notify companies when the person dies. If you work in a hospice or similar care setting, your organisation may offer to help your residents or patients register their life. 

You will need to get permission from the individual to provide all their personal details to register their life. We will ask you to confirm you have the authority to act for them.  

You will need to add the following information about the person whose life you are registering. 

  • Their title, name, email and date of birth.
  • Your relationship to them.
  • Their address.
  • Their previous addresses if they have not lived at their current address for 3 years or more.
  • The ownership status of the property. Utilities and insurance providers often request this information to process notifications.
  • If they have a partner and, if so, the partner’s name, email and phone number. If you are the partner we will prefill your details from the ones you have already provided. 
  • If they have a will and, if so, the name, email and phone number of any executor(s). You can choose if the executor has full access or read-only access. You can also upload a copy of their will and indicate who you want it to be visible to. 
  • You can also upload any funeral plan, insurance policy or other relevant documents and choose who you want them to be visible to.
  • You can add the contact details of any other person you want to tell about the life registration, so that they can take action to notify companies after the death of the person whose life you are registering.

We will send the person an email to tell them you have registered their life. They will be able to set up a Life Ledger account and access the life registration details. 

We will send an email to anyone you add to inform them that you have added them. They will then be able to set up a Life Ledger account and see the life registration details, in line with the access permissions you have set.

You can then start adding the companies the person whose life you are registering has accounts with. See ‘Adding companies and sending notifications’ for more information. 

6. Adding companies and sending notifications

Once you have registered the details of a death or a life you can add the companies the individual has accounts with. You can choose from our drop-down list of companies, or let us know if a company is missing. 

You will need to provide relevant information for each company. This will vary depending on the type of company and what they need to process notifications. Typically, you will need to provide the following information.

  • The account or policy number, or username of the deceased.
  • For financial organisations: sort code; card number, National Insurance number
  • For utilities: the products or services; meter readings
  • If you want to close or switch the account to another person (such as the partner of the deceased), and the details of who you want to switch it to.
  • If you want to transfer any points the deceased had with the company, 
  • Some ask for next of kin.

For life registrations, you can also use our paid service Life Ledger Discovery which is an open banking tool so you can pull from your bank account the details of companies you have accounts with. See the section ‘Open banking: Life Ledger Discovery’ for more information.   

Sharing your information with service providers

The purpose of the service is to provide the relevant details of the deceased to multiple service providers in one transaction. We will only pass on information that the service provider requires.

The main way to send the information is when you send notifications through our platform. If you get help from our Customer Support team they may need to call the service providers and provide the information over the phone or directly into their system using an online form. Service providers who accept notifications from our platform will be able to access a portal to view the notification information on our platform. 

When you notify them of a death, the service providers also need your name and contact details, both to know who has made the notification and in case they need to contact you. 

Some service providers also require a copy of your ID document. If this is the case, and you have already uploaded it, we will share this with them on their request. If you have not uploaded it you will need to do so.

Sharing collaborator information with service providers

If someone adds you to a registered death as a partner, executor, administrator or legal representative, your details will be included in the notifications sent to some service providers. If you are any other type of collaborator, your details will not be shared with service providers.

Messaging function to contact us and service providers

There is a messaging function in our platform where you can contact us and a service provider, and we and the service provider can contact you.  

This is only available to service providers who accept automated notifications from our platform. Service providers who require manual notifications have no access to the messaging function.

In most cases your notification is delivered directly to the service provider and they will contact you with any further questions or next steps. This may be a message sent through our platform’s messaging function or through their own communication channels. Where there is an issue with the automated notification, in some cases our customer support can help. See ‘Customer support’ for more details. 

7. Customer support

There are different ways you can contact us for help. In your account there is a messaging function, see the section Messaging function to contact us and service providers’ for more information. You can also email us or use the ‘contact us’ form on our website at any time. During office hours you may also be able to contact our customer support team directly using our online chat. If this functionality is not available (such as  outside office hours or if we are experiencing high chat volumes) you can also leave us a chat message. 

We store and manage any correspondence and associated notes on our back-end systems and Zendesk. 

In some cases, where there are issues with automated notifications, customer support staff are able to make a phone notification to a service provider on your behalf. They will add any relevant notes into our system and contact you with any further questions or next steps.  

In some cases customer support staff are able to fill in an online form on your behalf. Where possible, they will send you a copy of this or otherwise make it available to you. They will add any relevant notes into our system and contact you with any further questions or next steps.

If there are technical issues or bugs on our platform or within your account, our technical team may need access to your account to understand what isn’t working and to fix it. 

8. Open banking: Life Ledger Discovery

This is a paid service that allows you to connect to your bank account through our partner Nordigen (a GoCardless company). Through them you connect to your bank account and pull through to your Life Ledger account the details of companies you have accounts with. The information can vary depending on the bank, but typically includes the following.

  • Bank being accessed: bank name; number; sort code; name on account
  • Transaction information from the last 12 months: date; company name; account or payment reference number maybe; amount paid
  • Balance information: we are provided this information automatically but as we do not want or need it, we immediately delete it, and do not use or store it. 

You will need to give Nordigen permission to access your bank account and to share the data with your Life Ledger account, as well as accept Nordigen’s terms and conditions. Under data protection law they are independently responsible for telling you about their data collection and use, and for looking after your data in line with the law. We recommend you read their privacy notice which will be linked to from the permission screen.  

The permission screen will say that we have access to your bank account for 90 days. We are unable to change this and do not routinely access your bank account. The only way we can access your bank account and pull through the data is if you start the open banking process from your Life Ledger dashboard. 

9. Retention and deleting your account or information

As set out above in ‘Creating your account’ we may hold the personal data of several individuals in relation to one registered death or life. This means that what we need to keep and what we are able to delete will vary depending on the individual’s role in the death or life registration and whether they also have their own Life Ledger account or not. 

If you have a Life Ledger account and own a registered death or life, you may have options to delete your account and all the information in it. However, if you have sent notifications in a death registration, we will make your account inaccessible but we will need to archive and keep your data for a further seven years as it provides an evidence trail of who notified which companies of the deceased. This is in case we are challenged by anyone connected to the deceased or if the authority of the notifier is questioned. As this is a complex topic with many different scenarios to consider, we are currently finalising our approach to retention and deletion, particularly for those added to a registered life or death, and so for the moment our decisions are case-by-case.

For life registrations that you pay for, if you do not renew a subscription, we will keep your information for 6 years after the renewal date. This is in case you decide to reactivate the life registration or use one of our other services.  

10. Marketing

When you sign up for an account you are able to opt out of us sending you emails about other Life Ledger products and services. 

For our business marketing we collect your contact details:

  • directly from you;
  • through LinkedIn;
  • from relevant publicly-available websites.

You can unsubscribe at any time using the link in the email, or by contacting us on privacy@lifeledger.com 

11. Data sharing

Your data gets shared, viewed or is accessible in the following ways to the following individuals or organisations.

  • Other people you add to a registered death or life: if they go on to set up their own account, they will be able to access data in the registered death or life. The name, email and relationship to the deceased for all collaborators is visible to all other collaborators. The phone number for the surviving partner, legal representative, administrator and executor is also visible, as this is passed onto service providers in notifications. 
  • Service providers: when you send notifications (as set out in ‘Adding companies and sending notifications’); when you contact them using the messaging function within the platform (as set out in ‘Messaging function to contact us and service providers’).
  • Life Ledger customer support: when you contact us using the messaging function within the platform (as set out in ‘Messaging function to contact us and service providers’); when you contact us by email, contact form, chat or phone and we need to access your account to help you (as set out in ‘Customer support’). 
  • Life Ledger technical support: when there are issues or bugs that we need to fix, and we need to access your account to do so (as set out in Customer support’).
  • Credit reference agency: as part of identity checks (as set out in ‘Adding companies and sending notifications’ > ‘Identity check’).
  • Partners who advertise with us: as analytics for them when you click through to their website from within our platform, if they have analytics enabled on their website for this purpose; when you choose to arrange a callback with a partner offering this option from within our platform; when you choose to also share some information with the partner to help them plan for the call (as set out in ‘Adding companies and sending notifications’ > ‘Companies who advertise with us’). 
  • Stripe and GoCardless: when you pay for our products. You will see a message in the platform telling you that you are being transferred to one of these payment providers.
  • Nordigen (a GoCardless company): if you use the open banking feature for life registrations (as set out in ‘Open banking: Life Ledger Discovery’).
  • Other business support service providers: to run our business we use some third-party organisations, for data storage, customer support, payment, business partner contacts, analytics, marketing emails, platform and website development, technical support, and financial, legal and data protection advice.  

Legal obligations

We may disclose your personal information if we, in good faith, believe that we are required to do so by law, regulation or the order of court or other legitimate government body. 

If we sell our business or assets

We may have to share personal information with any person or legal entity to whom we sell or transfer (or start discussions with to sell or transfer) our business or any part of it.   

12. Data location 

We keep all our user data in the UK. Some of the service providers we use are located in other countries. Where this is the case we have agreements with them that include legally-required clauses to cover any transfer of data to other countries. 

13. Analytics

We use analytics on our website and on our platform. We use what is known as a ‘cookie management tool’ to manage this and any permissions you give for analytics. Please see the tool on the website and this page for more information: https://lifeledger.com/cookies/ 

14. Your privacy rights

To make any rights request, please contact privacy@lifeledger.com  

Access rights

You are entitled to know what personal information we hold about you and to receive a copy of it. By logging into your account you can see all the information you have provided us in relation to our services (except the ID verification information which we can provide on request). 

If you receive an email from us to tell you that someone else has added you to a registered death or life, but you do not set up your own Life Ledger account: the data we hold about you will be your name and contact details, and your relationship to the deceased or person registering a life. 

Correction rights

You are entitled to correct personal information we hold about you that is inaccurate. You can correct most of the information in your account that you have provided.

Deletion rights

In certain circumstances you are entitled to ask us to delete the personal information we hold about you. As set out above deletion is complicated! 

If you would like us to delete your account or other information, please contact us at privacy@lifeledger.com. There may be information that we are unable to delete for legal reasons. For more information, please see the section above ‘Retention and deleting your account and information’ as well as the ‘Legal obligation’ information below in the section ‘GDPR lawful bases’.

Objection rights

In certain circumstances you are entitled to object to us processing your personal information. If you receive any marketing, there will always be an unsubscribe option.

Restriction rights

In certain circumstances you are entitled to ask us to restrict our processing of your personal information. You can ask us to do this if:

  • you dispute the accuracy of your personal information
  • our processing is unlawful, but you prefer restriction to deletion
  • we no longer need the information, but you need it for legal reasons
  • you have objected to our processing and we are still dealing with this objection

Portability rights

In certain circumstances you are entitled to receive the personal information you have provided us in a structured, commonly used and machine-readable format.

Complain to the ICO

You can also complain to the Information Commissioner’s Office (ICO) who is responsible for making sure that UK organisations comply with the law on handling personal information – https://ico.org.uk/global/contact-us/. 

15. GDPR lawful bases

UK data protection law requires an organisation to have a lawful basis for its personal information collection and use, and there are several lawful bases available.

Performance of a contract

When you set up and use our services, almost all the personal information collection and use is necessary to provide the service. 

If you provide us your contact details to ask us a question, request more information or contact our Customer Support, we use your details to reply and resolve any issues.

Legitimate interests

Some personal data collection and use is in our legitimate business interests. To use this lawful basis we assess both our interests and yours, to make sure that what we’re doing does not cause any unjustified privacy intrusion.

Examples: identity checks; fraud prevention and reporting; marketing campaign records; records of notifications sent to service providers.

Legal obligation

We have legal obligations to collect, use and keep certain information for certain purposes.

Examples: diligence on corporate customers; records of who has unsubscribed from marketing.

Marketing: if you have provided us your contact details to hear about Life Ledger and its services and you no longer want to hear from us, we are obliged by law to stop contacting you. To meet this legal obligation we will add your details to a suppression list so you no longer hear from us. 

16. Contact us

Email: privacy@lifeledger.com 

Post: Life Ledger Limited, Rame Innovation Hub, Antony, Cornwall, PL11 3AB.

17. Information for service providers

If you use our portal or API to access notifications, we will need your title, name, organisation and contact details to set up an account.

Your admin will be able to add other users, and the admin can see all activity and any communications with individuals or Life Ledger. 

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