Privacy Policy

This privacy policy explains how Thelema (“we”, “us”, or “our”) collects, uses, stores, and protects personal data in connection with our will book transfer service for UK solicitors. It applies to data we receive from solicitors who are winding down their practice, as well as personal data contained within the will books and client records that are transferred to us.

1. Who we are

Thelema is a UK service that helps solicitors transfer their will books when retiring or winding down their practice. We take on the duty of care for former clients’ wills and manage all related client contact in accordance with UK data protection law and Solicitors Regulation Authority (SRA) guidance on practice closure.

For data protection purposes, Thelema is the data controller of the personal data described in this policy. If you have any questions about this policy or how we handle your data, please contact us at enquiries@thelema-wills.com.

2. What personal data we collect

We collect and process the following categories of personal data:

• Solicitor contact details: name, practice name, email address, telephone number, and professional address.
• Will book and client records: names, addresses, contact details, and other personal information of the former clients whose wills are transferred to us.
• Will contents: personal data contained within the wills themselves, which may include information about family members, executors, beneficiaries, and financial arrangements.
• Communication records: emails, call notes, and other correspondence between us and solicitors or former clients.

3. How we use personal data

We use personal data for the following purposes:

• To fulfil our contractual obligations under the will book transfer agreement with the transferring solicitor.
• To manage and store wills securely, and to discharge the duty of care owed to former clients.
• To contact former clients when there is a genuine, specific reason to do so — for example, to notify them of the transfer, to highlight a potential issue with their will, or to offer them the opportunity to update their will at a reduced rate.
• To comply with legal and regulatory obligations, including UK GDPR, SRA guidance, and our obligations as an ICO-registered data controller.

4. Legal basis for processing

We process personal data on the following legal bases under UK GDPR:

• Contractual necessity: processing is necessary to perform our contract with the transferring solicitor.
• Legal obligation: processing is necessary to comply with our legal and regulatory duties as a data controller and with SRA guidance.
• Legitimate interests: where we contact former clients about their wills, this is in our legitimate interest of discharging the duty of care, balanced against their rights and expectations.

5. How we store and protect data

All personal data is stored and processed within the United Kingdom. We use UK-based secure storage providers and maintain appropriate technical and organisational security measures to protect data against unauthorised access, loss, or destruction. These measures include encrypted data transmission, access controls, and regular security reviews.

6. How long we keep data

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including any legal, accounting, or regulatory requirements. Will books and client records are retained in accordance with SRA guidance on file retention at practice closure. When data is no longer required, it is securely deleted or anonymised.

7. Sharing personal data

We do not sell personal data. We may share data with:

• Our UK-based secure storage and IT service providers, under strict confidentiality and data processing agreements.
• Regulators, law enforcement, or other authorities where required by law.

8. Your rights

Under UK data protection law, you have the right to:

• Access the personal data we hold about you.
• Request correction of inaccurate or incomplete data.
• Request erasure of your personal data in certain circumstances.
• Object to or restrict certain types of processing.
• Request transfer of your data to another controller.
• Lodge a complaint with the Information Commissioner’s Office (ICO).

To exercise any of these rights, please contact us at enquiries@thelema-wills.com.

9. Cookies and analytics

Our website does not use third-party analytics or tracking cookies. We may use essential cookies required for the website to function correctly. If we introduce analytics in the future, we will update this policy and seek appropriate consent where required.

10. Changes to this policy

We may update this privacy policy from time to time to reflect changes in our practices or legal requirements. The latest version will always be available on this page, together with the date it was last updated.

11. Contact us

If you have any questions about this privacy policy or how we handle your personal data, please contact us:

Email: enquiries@thelema-wills.com
Website: thelema-wills.com