Yes, cemetery trusts have weird and wonderful practices when it comes to burial records. Mostly the bigger organizations (like councils) tend to be aware of current legislation and stay compliant with that legislation in terms of record-keeping, but many of them have inherited responsibility for other smaller cemeteries over the years where the record-keeping was pretty poor. The small cemeteries connected to churches, small towns, private landowners etc are probably still a problem for record-keeping, no matter what the current rules are. In particular, early cemeteries when established had to identify people as trustees of the cemeteries. However, over the years, those people have died and been replaced by others without ever telling the government. So there are cemeteries out there still operating whose official trustees are now all dead. So it is a mystery who might even be maintaining the burial register any more. Of course it will not be a mystery to local folk or local funeral directors who probably know that it's "Charlie Smith who looks after the cemetery", but for everyone else, it's a mystery. Kerry