A credit union is a member-owned financial cooperative, democratically controlled by its members, and operated for the purpose of promoting thrift, providing credit at competitive rates, and providing other financial services to its members. Data collection, processing and use are conducted solely for the purpose of carrying out the abovementioned objectives. This Privacy Notice is to provide you with information regarding the processing of information about you for account related purposes and other general purposes and to provide you with information on further processing that may be necessary where you apply for a loan with us.
Our contact details are:
Address: Crossmaglen Credit Union Limited, 40 Cardinal O’Fiaich Square, Crossmaglen, Newry BT35 9HQ
Contact Person: Data Protection Representative
Crossmaglen Credit Union is committed to protecting the privacy and security of your personal data. This privacy notice describes how we collect and use personal data about you during and after your relationship with us.
What personal data do we use?
We may collect, store, and use the following categories of personal data about you:
• Your name, address, date of birth, email, telephone, financial data, status and history, transaction data, contract data, details of the credit union products you hold/held with us and have held with us, signatures, identification documents, photo on system, salary, occupation, accommodation status, source of funds, Politically Exposed Status, mortgage details, previous addresses, spouse, partners, nominations, Tax Identification Numbers (TIN)/National Insurance numbers, passport details, driver’s licence, interactions with credit union staff and officers on the premises, by phone, or email, current or past complaints, CCTV footage, telephone answering machine recordings, results of any credit search completed by you in support of an application.
The purposes for which we use your personal data:
The credit union will use your personal data to assist it in carrying out the following:
• To open and maintain an account for you
• To meet our obligations to you under the Credit Union’s Standard Rules
• To contact you in respect of your account and any product or service you avail of
• To comply with our legal obligations for example anti-money laundering, to identify connected borrowers
• Assessing your loan application and determining your creditworthiness for a loan;
• Verifying the information provided by you in the application;
• We are obliged to purchase loan protection and life savings protection from ECCU;
• Administering the loan, including where necessary, to take steps to recover the loan or enforce any security taken as part of the loan.
• We may use credit scoring techniques and other automated decision making systems to either partially or fully assess your application.
• Meeting legal and compliance obligations and requirements under the rules of the credit union.
• To comply with regulatory requirements to determine whether you are a connected borrower or related party borrower.
We may also collect, store and use the following “special categories” of more sensitive personal data:
• Information about your health, including any medical condition, health and sickness (See Insurance for further details)
We need all the categories of information in the list above to allow us to; identify you, to contact you and in order that we perform our contract with you.
We also need your personal identification data to enable us to comply with legal obligations. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data.
How we use particularly sensitive personal data
”Special categories” of particularly sensitive personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data. We may process special categories of personal data in the following circumstances:
1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations and in line with our data protection policy.
3. Where it is needed in the public interest, and in line with our data protection policy.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
How secure is my information with third-party service providers?
All our third-party service providers are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes unless they are deemed to be controllers in their own right . We only permit them to process your personal data for specified purposes and in accordance with our instructions. Usually, information will be anonymised but this may not always be possible. The recipient of the information will also be bound by confidentiality obligations.
If you fail to provide personal data
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or we may be prevented from complying with our legal obligations.
Change of purpose
You can be assured that we will only use your data for the purpose it was provided and in ways compatible with that stated purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We sometimes use systems to make decisions based on personal data we have (or are allowed to collect from others) about you. This information is used for loan assessment and anti-money laundering purposes and compliance with our legal duties in that regard.
Automated decision making
We use systems to make automated decisions based on personal information we have – or are allowed to collect from others – about you or your organisation. When you apply for a loan, we use data from different sources to look at your ability to repay the loan. We also use information provided by you and information from third parties. The information we process for automated lending decisions includes Income, financial statements, transaction history, salary, spending and bills, internal credit rating, other loans held by you. In certain circumstances you can object to a decision based on automated processing.
Data Retention Periods
We will only retain your personal data for as long as necessary to fulfil the purpose(s) for which it was obtained, taking into account any legal/contractual obligation to keep it. Where possible we record how long we will keep your data, where that is not possible, we will explain the criteria for the retention period. This information is documented in our Retention Policy.
Once the retention period has expired, the respective data will be permanently deleted. If you require further information please contact us. Please see our data retention schedule on www.crossmaglencu.com or on request.
Please see some of our retention periods below.
• Evidence of identity checks to be maintained for 6 years after an individual ceases to be a member of the credit union;
• Details of member transactions are maintained for a period of 10 years after the transaction;
• Loan application information is maintained for a period of 6 years from the discharge, final repayment or transfer of the loan and 12 years where the document is under seal;
• Forms and records will be retained in individual member files for 6 years after the relationship with the member has ended.
Planned data transmission to third countries
There are no plans for a data transmission to third countries. However, please note that to register for online services (through a verification process) with Crossmaglen Credit Union, your mobile phone number may be transmitted outside the EU. This verification process is undertaken for us by a company called Plivo who are based in the United States of America. We will ensure that your personal data is treated by Plivo in a way that is consistent with and which respects the EU and UK laws on data protection.
Updates to this notice
We will make changes to this notice from time to time, particularly when we change how we use your information, and change our technology and products. You can always find an up-to-date version of this notice on our website at www.crossmaglencu.com or you can ask us for a copy.
Our use and sharing of your information
We will collect and use relevant information about you, your transactions, your use of our products and services, and your relationships with us. We will typically collect and use this information for the following purposes:
Fulfilling contract This basis is appropriate where the processing is necessary for us to manage your accounts and credit union services to you
Administrative Purposes: We will use the information provided by you, either contained in this form or any other form or application, for the purpose of assessing this application, processing applications you make and to maintaining and administer any accounts you have with the credit union.
Third parties: We may appoint external third parties to undertake operational functions on our behalf. We will ensure that any information passed to third parties conducting operational functions on our behalf will do so with respect for the security of your data and will be protected in line with data protection law.
Security: In order to secure repayment of the loan, it may be necessary to obtain security such as a charge on your property or other personal assets.
Credit Assessment: When assessing your application for a loan, the credit union will take a number of factors into account and will utilise personal data provided from:
• your application form or as part of your loan supporting documentation;
• your existing credit union file;
The credit union then utilises this information to assess your loan application in line with the applicable legislation and the credit unions lending policy.
Guarantors: As part of your loan conditions, we may make the requirement for the appointment of a guarantor a condition of your loan agreement in order that the credit union ensures the repayment of your loan. Should your account go into arrears, we may need to call upon the guarantor to repay the debt in which case we will give them details of the outstanding indebtedness. If your circumstances change it may be necessary to contact the guarantor.
Irish League of Credit Unions (ILCU) Affiliation: The ILCU (a trade and representative body for credit unions in Ireland and Northern Ireland) provides professional and business support services such as marketing and public affairs representation, monitoring, financial, compliance, risk, learning and development, and insurance services to affiliated credit unions. As this credit union is affiliated to the ILCU, the credit union must also operate in line with the ILCU Standard Rules (which members of the credit union are bound to the credit union by) and the League Rules (which the credit union is bound to the ILCU by). We may disclose information in your application or in respect of any account or transaction of yours from the date of your original membership to authorised officers or employees of the ILCU for the purpose of the ILCU providing these services to us.
The ILCU Savings Protection Scheme (SPS): We may disclose information in any application from you or in respect of any account or transaction of yours from the date of your original membership to authorised officers or employees of the ILCU for the purpose of the ILCU providing these services and fulfilling requirements under our affiliation to the ILCU, and the SPS.
The Privacy Notice of ILCU can be found at www.creditunion.ie
For the processing of electronic payments services on your account (such as credit transfers, standing orders and direct debits), the Credit Union is a participant of CUSOP (Payments) DAC (“CUSOP”). CUSOP is a credit union owned, independent, not-for-profit company that provides an electronic payments service platform for the credit union movement in Ireland. CUSOP is an outsourced model engaging third party companies, such as a Partner Bank, to assist with the processing of payment data.
Electronic Payments [not through CUSOP]: If you use our electronic payment services to transfer money into or out of your credit union account or make payments through your debit card into your credit union account, we are required to share your personal data with our electronic payment service provider First Trust Bank/Danske Bank.
Insurance: As part of our affiliation with the ILCU, we purchase insurance from ECCU Assurance DAC (ECCU), a life insurance company, wholly owned by the ILCU. This includes Life Savings (LS), Loan Protection (LP), and optional related riders (where applicable).
If you choose to take out a loan with us, it is a term of your membership, by virtue of our affiliation with the ILCU that the credit union will apply to ECCU for Loan Protection (LP). In order that we apply for LP it may be necessary to process ‘special category’ data, which includes information about your health. This information will be shared with ECCU to allow it deal with insurance underwriting, administration and claims on our behalf.
Member Service: To help us improve our service to you, we may use information about your account to help us improve our services to you.
Incapacity to Act on your account: The Credit Unions (Northern Ireland) Order 1985 (as amended) provides, in the circumstances where you become unable to transact on your account, due to a mental incapability and no person has been legally appointed to administer your account, that the Board of Director may allow payment to another who it deems proper to receive it, in order that the money be applied in your best interests. In order to facilitate this, medical evidence of your incapacity will be required which will include data about your mental health. This information will be treated in the strictest confidentiality.
Our legal duty: This basis is appropriate when we are processing personal data to comply with UK or Northern Ireland Law
Tax liability: We may share information and documentation with domestic and foreign tax authorities to establish your liability to tax in any jurisdiction. Where a member is tax resident in another jurisdiction the credit union has certain reporting obligations to HM Revenue and Customs (HMRC) under the Common Reporting Standard. HMRC will then exchange this information with the jurisdiction of tax residence of the member. We shall not be responsible to you or any third party for any loss incurred as a result of us taking such actions. The legal basis upon which we do this is compliance with HM Revenue and Custom’s Automatic Exchange of Information standard. We may also share information in respect of dividends and interest payments to members to HMRC where required by law.
Regulatory and statutory requirements: To meet our duties to regulators (the Financial Conduct Authority (FCA) and the Prudential Regulation Authority ((PRA), we may allow authorised people to see our records (which may include information about you) for reporting, compliance and auditing purposes. For the same reason, we will also hold the information about you when you are no longer a member. We may also share information with certain statutory bodies such as Department for the Economy (DfE), the Financial Services Compensation Scheme (FSCS) and Financial Ombudsman Service (FOS) if required by law.
Compliance with our anti-money laundering and combating terrorist financing obligations: The information provided by you will be used for compliance with our customer due diligence and screening obligations under anti-money laundering and combating terrorist financing obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and associated legislation.
Audit: To meet our legislative and regulatory duties to maintain audited financial accounts, we appoint an external auditor. We will allow the external auditor to see our records (which may include information about you) for these purposes.
Connected Party Borrowers: We are obliged further to regulatory obligations to identify where borrowers are connected in order to establish whether borrowers are acting together to achieve an aggregate loan that exceeds the limits set out in our lending policy.
Nominations: The Credit Unions (Northern Ireland) Order 1985 (as amended) allows members to nominate a person(s) to receive a certain amount from their account on their death, subject to a statutory maximum. The credit union must record personal data of nominees in this event.
Legitimate interests: A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
Credit Assessment: We may use information from the Electoral Register and other public sources. When you apply to us for a loan, we may check the following records about you:
(a) our own records and
(b) Those at fraud prevention agencies.
Our legitimate interest: The credit union, for its own benefit and therefore the benefit of its members, must lend responsibly and will use your internal credit scoring information in order to determine your suitability for the loan applied for.
The searches may also assess your application for the purpose of verifying identities, to prevent and detect crime and money laundering. We may also make periodic searches at fraud prevention agencies to manage your account with us as part of our ongoing customer due diligence.
If you give us false or inaccurate information and we suspect or identify fraud we will record this and may also pass this information to fraud prevention agencies and other organisations involved in crime and fraud prevention.
Debt Collection: Where you breach the loan agreement we may use the service of a debt collection agency, solicitors or other third parties to recover the debt. We will pass them details of the loan application in order that they make contact with you and details of the indebtedness in order that they recover the outstanding sums.
Our legitimate interest: The credit union, where appropriate will take necessary steps to recover a debt to protect the assets and equity of the credit union
Judgements Searches: We may carry out searches in Belfast/London Stubbs Gazette(s) in order to assess your credit worthiness to repay a loan Our legitimate interest: The credit union, for its own benefit and therefore the benefit of its members, must lend responsibly and will use your internal credit scoring information in order to determine your suitability for the loan applied for. In carrying out such a search we can better determine your overall financial position in order to lend to you.
CCTV: We have CCTV footage installed on the premises with clearly marked signage. The purpose of this is for security. Our legitimate interest: With regard to the nature of our business, it is necessary to secure the premises, property herein and any staff/volunteers/members or visitors to the credit union.
Your Rights in connection with your personal data are to:
Find out whether we hold any of your personal data and if we do, to request access to that data and to be furnished a copy of that data. You are also entitled to request further information about the processing.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you rectified.
Request erasure of your personal information. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
Request the restriction of processing of your personal information. You can ask us to suspend processing personal data about you, in certain circumstances.
Where we are processing your data based solely on your consent you have a right to withdraw that consent at any time and free of charge.
Request that we: a) provide you with a copy of any relevant personal data in a reusable format; or b) request that we transfer your relevant personal data to another controller where it’s technically feasible to do so. ‘Relevant personal data is personal data that: You have provided to us or which is generated by your use of our service, which is processed by automated means and where the basis that we process it is on your consent or on a contract that you have entered into with us.
You have a right to complain to the Information Commissioners Office (ICO) in respect of any processing of your data by;
Tel: 028 9027 8757 or 0303 123 1114 Email: firstname.lastname@example.org
Post: ICO, 3rd Floor, 14 Cromac Place, Belfast, BT7 2JB
**Please note that the above rights are not always absolute and there may be some limitations.
If you want access and or copies of any of your personal data or if you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we send you a copy/a third party a copy your relevant personal data in a reusable format please contact the Data Protection Representative in writing using their contact details below.
There is no fee in using any of your above rights, unless your request for access is clearly unfounded or excessive. We also reserve the right to refuse to comply with the request in such circumstances.
We may need to verify your identity if we have reasonable doubts as to who you are. This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Ensuring our information is up to date and accurate
We want the service provided by us to meet your expectations at all times. Please help us by telling us straightaway if there are any changes to your personal information. If you wish to avail of either of these rights, please contact us at Crossmaglen Credit Union Limited, 40 Cardinal O’Fiaich Square, Crossmaglen, Newry BT35 9HQ