Legal
Privacy Policy
This policy explains how A. Rafael Advisory handles personal data, both for people who contact us and for individuals whose details arise in the course of our research.
Who we are
A. Rafael Advisory is a specialist probate genealogy and tracing practice registered in England and Wales, company number 17002818, with its registered office at Newminster House, 27 to 29 Baldwin Street, Bristol BS1 1LT.
We are registered with the Information Commissioner's Office as a data controller under registration number 00013027972.
For most of our work we act as a data controller, because we determine the purposes and means of the research we carry out. In some circumstances, where we act strictly on the instructions of a firm or authority, we may act as a processor. Where you are unsure which applies to a particular matter, please ask us.
This policy was last updated on 24th July 2026.
The personal data we process
We process personal data about two broad groups of people.
People who contact us. If you make an enquiry, instruct us, or correspond with us, we process your name, the firm or organisation you act for, your email address, your telephone number, and the content of your correspondence with us.
People who are the subject of our research. In the course of probate and tracing research we process personal data about individuals we have been instructed to identify or locate, and about their relatives.
We also process information about deceased individuals. Data protection law in the United Kingdom does not apply to the personal data of people who have died, but we treat such information with the same care, because it is frequently linked to living relatives.
Where we obtain personal data
Where you have contacted us directly, we obtain your personal data from you.
Where you are the subject of our research, we will usually have obtained your personal data from publicly available sources, official records, or information lawfully provided to us by the firm, executor, trustee, public authority or other organisation instructing us to carry out our research.
Why we process personal data, and our lawful basis
We process personal data in connection with the probate research and related services we provide, including establishing and evidencing legal entitlement, locating individuals, obtaining relevant information and documents, and fulfilling instructions received from our clients.
Where you have contacted or instructed us directly, we process your personal data where necessary to perform a contract with you or to take steps at your request before entering into a contract.
Where you are the subject of our research, we generally rely on our legitimate interests, and those of our clients, in carrying out probate research and related services. We consider that this processing is necessary, proportionate and does not override your rights and freedoms. You have the right to object to processing carried out on this basis. Please see Your Rights below for further information.
Where we are required to process personal data to comply with a legal or regulatory obligation, we do so on that basis.
We do not sell personal data, and we do not use personal data for automated decision-making or profiling that produces legal or similarly significant effects.
Special category data
In limited circumstances, our work may involve processing special category personal data where this is necessary for the services we provide.
Where we process such data, we will do so only where permitted by applicable data protection law and only to the extent necessary for the relevant purpose.
Who we share personal data with
We share personal data only where it is necessary to provide our services, to comply with our legal obligations, or where otherwise permitted by applicable law. This may include our clients, public authorities, professional advisers, trusted service providers, and other third parties where disclosure is necessary for the purposes of carrying out our work.
We require third parties processing personal data on our behalf to do so securely, in accordance with our instructions and applicable data protection law.
We do not disclose your personal data to other parties unless we are required or permitted to do so by law, or you have asked us to.
Transfers outside the United Kingdom
Where it is necessary to provide our services, we may transfer personal data outside the United Kingdom.
Where personal data is transferred internationally, we take appropriate steps to ensure it remains protected in accordance with applicable data protection law. This may include relying on adequacy regulations, contractual safeguards, or other lawful transfer mechanisms, as appropriate.
You may contact us for further information about the safeguards we apply to international transfers.
How long we keep personal data
We retain research files and the personal data within them for 15 years following the conclusion of a matter. We do so because claims relating to estates and trusts may arise many years after administration, and our research may need to be relied upon or explained long after it was carried out.
Enquiries that do not result in an instruction are generally retained for 12 months, after which they are securely deleted unless there is a legitimate reason to retain them for longer.
At the end of the applicable retention period, we securely delete or anonymise personal data unless we are required or permitted by law to retain it for longer.
How we protect personal data
We maintain technical and organisational measures appropriate to the sensitivity of the information we hold. These include access controls, encryption of data in transit and at rest, secure disposal of physical and electronic records, confidentiality obligations on everyone acting for us, and contractual data protection terms with the suppliers and correspondents who process data on our behalf.
Your rights
You have the right to be told what personal data we hold about you and to receive a copy of it, to have inaccurate personal data corrected, to have personal data erased in certain circumstances, to ask us to restrict how we use your personal data, to receive certain personal data in a portable form, and to withdraw consent where we have relied on it.
You also have the right to object to our processing of your personal data where we rely on legitimate interests. If you object, we will stop processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms, or the processing is necessary for the establishment, exercise or defence of legal claims.
These rights are not absolute, and in some cases we may be unable to comply in full. For example, we may be unable to erase research that a personal representative must rely on to distribute an estate lawfully. Where that is the case we will explain why.
To exercise any of these rights, contact us using the details below. We will respond within one month. There is no charge.
Cookies and this website
This website does not set cookies, does not use analytics or advertising trackers, and does not profile visitors.
If you submit the enquiry form, the details you provide are sent to us by email and recorded in our enquiry management system. We use them only to respond to your enquiry and, where you go on to instruct us, to carry out the work. We do not add enquirers to marketing lists.
Our website is hosted by Vercel Inc. and our enquiry emails are delivered by Resend. Both process limited technical data, such as IP addresses in server logs, in order to deliver the service.
Changes to this policy
We may update this policy from time to time. The date at the top of this page shows when it was last revised. Where changes are significant, we will take reasonable steps to bring them to the attention of those affected.
How to contact us, and how to complain
For any question about this policy, or to exercise any of your rights, contact us at enquiries@rafaeladvisory.com, on 0333 772 4565, or by post at A. Rafael Advisory, Newminster House, 27 to 29 Baldwin Street, Bristol BS1 1LT.
If you are unhappy with how we have handled your personal data, please tell us first so that we have the opportunity to put it right. You also have the right to complain to the Information Commissioner's Office at any time. The ICO can be contacted at ico.org.uk, on 0303 123 1113, or at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.