Privacy Notice - How We Use Your Will Records

If we hold a Will for you (one you made with us, or one you asked us to keep safe), we may use a secure professional tool, Willsure, to give it an automatic "health check". This notice explains, in plain terms, what that involves, what information is looked at, and the choices you have.

The most important thing to know: you can object to your Will being analysed as part of our Will review process at any time and, if you do, we will stop using the Willsure service in relation to your Will.

[Firm Name] (the "Firm") is the data controller - the firm legally responsible for your information. The Firm is registered with the Information Commissioner's Office under registration reference [ICO registration number].

Our contact details for privacy matters: [insert DPO/privacy contact email and postal address].

We are authorised and regulated by the Solicitors Regulation Authority ("SRA") under SRA number [SRA number] and bound by professional obligations, including duties of confidentiality and legal professional privilege, which apply to everything in this notice in addition to our legal obligations arising under data protection law.

For Wills we hold in our secure Will bank, we use a tool called Willsure that reads the Will and highlights anything that might cause a problem later; for example, changes in your family circumstances the Will may not reflect, provisions that may benefit from review, potentially outdated drafting, or other indicators that a Solicitor should consider whether a review is appropriate.

A Solicitor at the Firm then reviews what the tool has flagged before anything at all happens - you will only ever hear about a result from a person, never from a computer decision. Often the outcome is simply reassurance that everything is in order.

No decision producing legal or similarly significant effects is made solely by automated means. Every assessment is reviewed by a Solicitor before any client-facing outcome, and the Solicitor may edit or reject the tool's output entirely. This keeps the processing outside the UK GDPR's rules on solely automated decision-making (Article 22).

We carry out these reviews because we believe it is both in your interests and ours to help identify Wills that may benefit from updating or review as circumstances and legislation change over time.

Our legal basis for carrying out these reviews is, primarily, that we have a legitimate interest in maintaining and reviewing Wills held within our Will bank and identifying circumstances where a review may benefit our clients (UK GDPR Article 6(1)(f)). We also rely on our legal obligations as solicitors to retain and review executed Wills under SRA and Money Laundering Regulations obligations (Article 6(1)(c)) where applicable.

Because Wills can contain sensitive information (see Section 3), we have carried out a Data Protection Impact Assessment ("DPIA") for this processing, as required under UK GDPR Article 35. A copy of the DPIA summary is available on request.

The tool looks only at documents we already hold lawfully for you: your Will (and any codicils), and the details within it; your name and address, your family circumstances, your executors, beneficiaries, and the make-up of your estate. Wills often mention private matters such as health, family relationships or personal wishes, and we treat that information with the strictest confidence.

Wills can also contain what data protection law calls "special category data" (UK GDPR Article 9) - for example, information about your health, mental capacity, family circumstances such as divorce or estrangement, or occasionally your religion. Where the Willsure tool analyses this kind of information, we rely on the condition in Article 9(2)(f) (the establishment, exercise or defence of legal claims) for the AI-assisted review, because the review is tied to the Firm's practice and your Will. The Firm has assessed and documented this condition as part of the DPIA.

We do not collect anything new about you for this purpose.

We do not sell your information. Where we use the Willsure service, information is processed on our behalf under contractual confidentiality, security and data protection obligations.

The Willsure tool is an online service operated under a formal contract with the Firm (a Data Processing Agreement under UK GDPR Article 28), which includes strict confidentiality and security obligations. Your Will is analysed securely within that service, and only authorised people at this Firm can see the results. Results are held in the Firm's own secure systems, and our review notes stay within the Firm.

Willsure acts as a data processor on our behalf and may use approved technology providers, including AI model providers, to assist in the analysis process. These sub-processors are bound by contractual confidentiality, security and data protection obligations, and are not permitted to use your information to train their models.

Where personal information is processed outside of the United Kingdom, appropriate safeguards are used in accordance with UK data protection law, including International Data Transfer Agreements (IDTAs) where applicable.

How the information moves: copies of Wills held in the Firm's document store are securely transferred to the Willsure platform for analysis; the results (a risk score, risk band and plain-English summary) are written back to the Firm's records; and a short daily digest is sent to the Firm's registered contact when Wills have been processed. All client-facing letters and emails are drafted in the platform but dispatched manually by a Solicitor - the Firm, not the tool, decides whether and when to contact you.

You can say no, at any time, for any reason. You do not need to explain why. If you tell us you'd prefer your Will not to be analysed, we will exclude it from the Willsure service and delete the analysis we hold for it, although we may retain limited records where required by law, regulation or professional obligations. Please be aware that this is a deliberate consequence of honouring your objection: once the analysis is deleted, the Firm will no longer be able to proactively identify when changes in the law or your circumstances mean your Will may need updating, and our ability to reach out to you for a review ends with the objection. Your Will itself remains safely stored in our Will bank regardless. Just contact us using the details below.

You can change your mind later, ask us to stop at any point, or (if it's appropriate) to resume.

If you're unhappy about anything in this notice or about how your information has been handled, you can complain to us directly, or to the Information Commissioner's Office (ico.org.uk, 0303 123 1113) or by post to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

As well as the right to object above, you can ask us for a copy of the information we hold, ask us to correct anything inaccurate, or ask us to delete information where the law allows. Requests are free and we will respond within one month.

You also have the right to object to this processing and we will consider any objection in accordance with data protection law.

Your Will itself is held in our Will bank for as long as our Will-retention practice provides; typically indefinitely, as you would expect for a document we keep safe for you.

The analysis we produce using the Willsure tool (the structured facts it extracts, the risk score and score history, and the plain-English summary) is kept for as long as we hold your Will. This is deliberate: the purpose of the analysis is to let us look after your Will properly over the years, so that if the law changes in a way that affects your circumstances (for example, changes to inheritance tax rules, or to the law relating to farms and family businesses), we can identify that your Will may need updating and invite you in to review it. Keeping the analysis is what allows us to tell you when you need to come and see us.

Separately, there is a short-lived "transient" layer created during each analysis - temporary copies of the document staged for processing, technical job logs, and intermediate outputs from the AI model. This is automatically purged on a short cycle once each analysis is complete; it serves no ongoing purpose and is not retained.

When your Will leaves our care (for example, if you ask us to return it, or it is dealt with on death), we delete the analysis.

If you ask us to stop analysing your Will, we delete or securely dispose of the analysis, unless you ask us to keep it for your own reference, in which case we will.

To object, opt out, ask a question or make a request:

Email: [privacy contact email]

Post: [Firm name], [postal address]

Tel: [telephone number]

This notice is part of our commitment to transparency about our use of technology. We will update it if our practices change and, where the change matters to you, we will tell you directly.