Cemetery Staff Conduct and Bereavement Service Procedures enquiry
Case reference FOI2026/01837
Received 28 August 2026
Published 6 October 2026
Request
I am submitting a request under the Freedom of Information Act 2000.
I am researching local authority cemetery operational practices and how burial authorities balance the operational and safety requirements of cemetery staff with the dignity, privacy and experience of bereaved families during burial services.
Please provide the following information relating to cemetery staff/operatives involved in burial services at your authority’s cemeteries.
1. Staff conduct and funeral etiquette
Please provide copies of any current policies, procedures, guidance documents, training materials or operational instructions relating to:
* expected conduct of cemetery staff during burial services;
* professional behaviour, discretion and sensitivity around mourners;
* maintaining dignity during funeral or committal services;
* interaction between cemetery staff and bereaved families during burial ceremonies;
* expectations regarding staff presence, visibility or positioning during burial services.
2. Staff presence and positioning during burial services
Please confirm whether cemetery staff are expected to remain present at the graveside throughout the duration of a burial service.
If staff are required to remain present, please provide any written guidance or procedures relating to:
* where cemetery staff should position themselves during a burial service;
* whether staff are expected to remain visible to mourners throughout the service;
* whether staff are expected to maintain a particular distance from mourners where practicable;
* avoiding unnecessary intrusion into the area occupied by mourners during the funeral or committal service, where operational requirements allow.
If no such written guidance exists, please confirm this.
3. Training provided to cemetery staff
Please provide details of any training provided to cemetery staff which covers:
* funeral etiquette;
* bereavement awareness;
* communication with mourners;
* sensitivity and professionalism during burial services;
* understanding the emotional impact of staff actions and positioning during funerals.
Please provide copies of any relevant training materials where available.
4. Risk assessments and operational requirements
Please provide copies of any risk assessments, method statements or operational assessments which address:
* the requirement for cemetery staff to remain present during burial services;
* the requirement for staff to remain visible to mourners;
* how staff presence is balanced against the privacy and dignity of bereaved families.
5. Use of external guidance
Please confirm whether your authority uses guidance, standards or training materials produced by external organisations, including but not limited to the Institute of Cemetery and Crematorium Management (ICCM), in relation to staff conduct during burial services.
If applicable, please provide details of:
* the guidance or training used;
* whether it is mandatory or advisory;
* whether it specifically addresses dignity, discretion, sensitivity or conduct around mourners.
Response
Thank you for your recent request under the Freedom of Information Act.
Please find the answers to your queries below:
I am writing to you under the Freedom of Information Act to request the following information:
I am submitting a request under the Freedom of Information Act 2000.
Please provide the following information relating to cemetery staff/operatives involved in burial services at your authority’s cemeteries.
1. Staff conduct and funeral etiquette
Please provide copies of any current policies, procedures, guidance documents, training materials or operational instructions relating to:
* expected conduct of cemetery staff during burial services;
* professional behaviour, discretion and sensitivity around mourners;
* maintaining dignity during funeral or committal services;
* interaction between cemetery staff and bereaved families during burial ceremonies;
* expectations regarding staff presence, visibility or positioning during burial services.
The Council follows guidance and codes of practice set by both the Institute of Cemetery and Crematorium Management (ICCM – https://www.iccm-uk.com/iccm/) and the Federation of Burial and Cremation Authorities (FBCA – https://www.fbca.org.uk/code-of-cremation-practice/).
2. Staff presence and positioning during burial services
Please confirm whether cemetery staff are expected to remain present at the graveside throughout the duration of a burial service.
If staff are required to remain present, please provide any written guidance or procedures relating to:
* where cemetery staff should position themselves during a burial service;
* whether staff are expected to remain visible to mourners throughout the service;
* whether staff are expected to maintain a particular distance from mourners where practicable;
* avoiding unnecessary intrusion into the area occupied by mourners during the funeral or committal service, where operational requirements allow.
If no such written guidance exists, please confirm this.
The Council does not hold any specific written guidance prescribing the exact location, visibility or distance that cemetery staff must maintain from mourners during burial services. Staff are expected to conduct themselves professionally and sensitively in accordance with relevant corporate policies and operational procedures.
3. Training provided to cemetery staff
Please provide details of any training provided to cemetery staff which covers:
* funeral etiquette;
* bereavement awareness;
* communication with mourners;
* sensitivity and professionalism during burial services;
* understanding the emotional impact of staff actions and positioning during funerals.
Please provide copies of any relevant training materials where available.
The requested training materials comprise proprietary course content developed and sold by a third-party training provider. Disclosure would be likely to prejudice the provider's commercial interests by undermining its ability to market and license the material commercially. Therefore, we have concluded that due to the nature of this matter and the commercial sensitivity of the requested documentation, the Council is of the view that this information is exempt from disclosure under Section 43(2) of the Freedom of Information Act 2000, as disclosure would be likely to prejudice the commercial interests of any legal person (including the public authority holding it), as well as to adversely affect their ability to participate competitively in a commercial activity.
Public Interest Factors in Favour of Disclosure
-
Disclosure would promote openness and transparency about how public funds have been spent on staff training.
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Disclosure would help the public understand the content and quality of training provided to staff and assess whether it represents value for money.
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There is a general public interest in accountability for decisions made by public authorities, including decisions to procure external training services.
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Disclosure would contribute to public confidence in the organisation's training and development arrangements.
Public Interest Factors in Favour of Maintaining the Exemption
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The information comprises commercially valuable training materials developed by a third-party provider at private expense and supplied under licence for use by the organisation. Disclosure would be likely to undermine the provider's ability to market and sell the materials commercially.
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Release into the public domain under FOIA would effectively provide unrestricted access to proprietary course content, potentially reducing the provider's competitive advantage and damaging its commercial position.
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There is a public interest in protecting legitimate commercial interests and ensuring that organisations can continue to procure specialist training from external providers without adversely affecting those providers' business interests.
-
Disclosure may discourage commercial suppliers from providing detailed materials to public authorities in the future or may result in increased costs to the public sector where suppliers seek to protect their intellectual property through more restrictive contractual arrangements.
Public Interest Test Conclusion
Having considered the competing public interests, the organisation recognises the importance of transparency regarding the expenditure of public funds and the training provided to its staff. However, in this case greater weight is attached to the public interest in protecting the legitimate commercial interests of the third-party provider.
The requested information consists of proprietary training materials which have independent commercial value. Disclosure would be likely to prejudice the provider's commercial interests by making valuable course content available to the wider public without charge. It is considered that the resulting harm to the provider's commercial position would outweigh the public interest benefits arising from disclosure.
Therefore, the public interest favours maintaining the exemption under Section 43(2) of the Freedom of Information Act 2000.
4. Risk assessments and operational requirements
Please provide copies of any risk assessments, method statements or operational assessments which address:
* the requirement for cemetery staff to remain present during burial services;
* the requirement for staff to remain visible to mourners;
* how staff presence is balanced against the privacy and dignity of bereaved families.
As above, the Council does not hold any specific written guidance prescribing the exact location, visibility or distance that cemetery staff must maintain from mourners during burial services. Staff are expected to conduct themselves professionally and sensitively in accordance with relevant corporate policies and operational procedures.
5. Use of external guidance
Please confirm whether your authority uses guidance, standards or training materials produced by external organisations, including but not limited to the Institute of Cemetery and Crematorium Management (ICCM), in relation to staff conduct during burial services.
If applicable, please provide details of:
* the guidance or training used;
* whether it is mandatory or advisory;
* whether it specifically addresses dignity, discretion, sensitivity or conduct around mourners.
As above, the Council follows guidance and codes of practice set by both the Institute of Cemetery and Crematorium Management (ICCM – https://www.iccm-uk.com/iccm/) and the Federation of Burial and Cremation Authorities (FBCA – https://www.fbca.org.uk/code-of-cremation-practice/).
Yours sincerely,
FOI Team
Guildford Borough Council
Documents
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