NEW GDPR Updates - Celebrant Info
What should celebrants do now?
I recommend that every celebrant checks the following:
1: Register with the ICO
or complete its official exemption assessment. Sole traders are included in the fee rules.
Click Here: ICO fee self-assessment
2: Update the privacy notice to include the new complaints process and explain:
What information is collected
Why it is needed
The lawful bases used
Who receives it
How long it is retained
Individual rights
How to complain
3: Create a short internal complaints procedure, even if the business consists of only one person
4: Review questionnaires
Only ask for information genuinely required ( I need to check our application questionnaire and make sure we aren't asking anything we don't need, do you think we need date of birth? to create or deliver the ceremony.
5: Set retention periods for:
Enquiries that do not proceed
Questionnaires and interview notes
Audio recordings
Ceremony drafts
Final scripts
Contracts and invoices
WhatsApp messages and downloaded attachment
6: Client Information:
Keep client information secure with strong unique passwords, multifactor authentication, encrypted or access-controlled storage and secure disposal.
7: Check cloud, transcription and AI tools:
Understand where information is stored, whether it is used to train systems, whether it leaves the UK and whether an appropriate data-processing agreement exists. Avoid entering identifiable ceremony information into consumer AI services without proper safeguards and transparency.
8: Obtain Separate Permission for Marketing:
Obtain separate, recorded permission before publishing photographs, testimonials, ceremony extracts or personal stories on websites and social media. Contractual permission to conduct a ceremony is not automatically permission to use someone’s story for marketing
9: Maintain a breach log:
A lost questionnaire, misdirected ceremony script or email sent to the wrong family could be a personal-data breach. Reportable breaches must be reported to the ICO without undue delay and within 72 hours of becoming aware of them. ICO 72-hour guidance
And finally…
The most urgent new action for celebrants (Celebrant Circle) is adding a clear data-protection complaints process. The broader fundamentals remain the same: collect only what you need, explain what you are doing, keep it secure, restrict sharing, retain it only as long as necessary and respect people’s rights.
Celebrant Circle
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