Privacy Notice of Blackpool Credit Union Limited
Our contact details are:
Blackpool Credit Union Limited, 5 Great William O’Brien St, Blackpool, Cork.
Phone: 021-450 1757
For Data Protection queries contact firstname.lastname@example.org
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.
Blackpool Credit Union is committed to protecting the privacy and security of your personal data. This privacy notices 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 information about you:
• Your name
• Date of birth
• Telephone details
• Financial data,
• Credit union account status and account history
• Transaction data
• Contract data
• Details of the credit union products you hold with us
• Identification documents
• Accommodation status
• Mortgage details
• Previous addresses
• Spouse / partner
• Tax Identification/PPS numbers
• Passport details / driving licence
• Interactions with credit union staff and officers on the premises, by phone, or email
• Current or past complaints
• CCTV footage.
We may also collect, store and use the following “special categories” of more sensitive personal information:
• 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 and 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 information.
If you fail to provide personal information
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.
The purposes for which we use your personal data:
• To open and maintain an account for you.
• To meet our obligations 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 obligation for example anti-money laundering obligations.
• In assessing your loan application and determining your creditworthiness for a loan.
• Verifying the information provided by you in your applications.
• In order to purchase loan protection and life savings protection from ECCU.
• Conducting credit searches and making submissions to Irish Credit Bureau and the Central Credit Register.
• Administering the loan, including where necessary, to take steps to recover the loan or enforce any security taken as part of the loan.
• To comply with Central Bank Regulations to determine whether you are a connected borrower or related party borrower.
• Providing updates on our loan products and services by way of directly marketing to you.
• When acting as an insurance intermediary or introducer, to meet our 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Planned data transmission internationally
We do not transfer personal information outside of the European Economic Area (EEA)
How we use particularly sensitive personal information
”Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal information 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 data 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.
We sometimes use systems to make decisions based on personal information we have (or are allowed to collect from others) about you. This information is used for loans assessment and anti-money laundering purposes and compliance with our legal duties in that regard.
Data Retention Periods
We will only retain your personal information 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. We document the reasons for our retention periods and where possible the retention periods themselves in our Retention Policy. Once the retention period has expired, the respective data will be permanently deleted.
Please note our data retention periods below:
• Accounting records required to be kept further to the Credit Union Act, 1997 (as amended) must be retained for not less than six years from the date to which it relates.
• The money laundering provisions of Anti-Money Laundering legislation require that certain documents must be retained for a period of five years after the relationship with the member has ended.
• We keep income tax records for a period of six years after completion of the transactions to which they relate.
• Credit agreements are retained for six years from date of expiration or breach, and twelve years where the document is under seal.
• CCTV footage which is used in the normal course of business (i.e. for security purposes) for one month
How do we use and share 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 for the following purposes:
Fulfilling a contract
This is appropriate where the processing is necessary for us to manage your accounts and credit union services.
• Administrative Purposes: We will use the information provided by you, contained in any form or application, for the purpose of assessing and processing the application and maintaining and administering 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 is treated with respect for the security of your data and will be protected in line with data protection law.
• 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 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 contained 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.
As part of our affiliation with the ILCU we carry insurance products from ECCU Assurance DAC (ECCU) which includes Life Savings (LS), Loan Protection (LP) and Disability Cover where it applies. New Ireland provide Death Benefit Insurance (DBI).
To administer these products and services we may pass your details to New Ireland and ECCU Assurance DAC (ECCU), a life insurance company, wholly owned by the Irish League of Credit Unions which exists to provide insurance to credit unions affiliated to the Irish League of Credit Unions.
It is a term of your membership, by virtue of our affiliation with the ILCU that we must apply to ECCU for Loan Protection (LP) if you choose to take out a loan with us. If covered, any outstanding sum will be repaid to the credit union by ECCU in the event of your death. In order that we apply for LP it may be necessary to process ‘special category’ data, which includes data about your health. This information will be shared with ECCU to allow it deal with insurance underwriting, administration and claims on our behalf.
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 any of your loan supporting documentation
• Your existing credit union file
• Credit referencing agencies such as the Irish Credit Bureau and the Central Credit Registrar
We utilise this information to assess your loan application in line with the applicable legislation and the credit unions lending policy.
To help us improve our service to you, we may use information about your account to help us improve our customer service.
This basis is appropriate when we are processing personal data to comply with an Irish or EU Law.
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 Revenue under the Common Reporting Standard. Revenue 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. Under the “Return of Payments (Banks, Building Societies, Credit Unions and Savings Banks) Regulations 2008” credit unions are obliged to report details to the Revenue in respect of dividend or interest payments to members, which include PPSN where held.
Regulatory and statutory requirements:
To meet our duties to the Regulator, the Central Bank of Ireland, we may allow authorised people to see our records (which may include information about you) for reporting, compliance and auditing (external and internal) 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 the Department of Finance, the Department of Social Protection and the Financial Services and Pensions Ombudsman Bureau of Ireland if required by law.
Purpose of the loan:
We are obliged to ensure that the purpose of the loan falls into one of our categories of lending.
Compliance with our anti-money laundering and combating terrorist financing obligations:
The information provided by you in any application 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 provisions of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 , as amended by Part 2 of the Criminal Justice Act 2013 (“the Act”)
Audit & Risk / Compliance:
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.
The Credit Union Act 1997 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. Where a member wishes to make a nomination, the credit union must record personal data of nominees in this event.
Where a loan is applied for in the sum of €500 or more, the credit union is obliged to make an enquiry of the Central Credit Register (CCR) in respect of the borrower. Where a loan is granted in the sum of €500 or more, the credit union is obliged to report both personal details and credit details of the borrower to the CCR.
Connected/Related Party Borrowers:
We are obliged, further to Central Bank Regulations to identify where borrowers are connected in order to establish whether borrowers pose a single risk. We are also obliged to establish whether a borrower is a related party when lending to them, i.e. whether they are on the Board/Management Team or a member of the Board/ Management teams family or a business in which a member of the Board /Management Team has a significant shareholding.
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 and Credit Reference Agencies:
When assessing your application for a loan, as well as the information referred to above in credit assessment, the credit union also utilises credit data from credit referencing agencies such as the Irish Credit Bureau and the Central Credit Registrar [See legal duty].
Our legitimate interest: The credit union, for its own benefit and therefore the benefit of its members, must lend responsibly and will use your credit scoring information in order to determine your suitability for the loan applied for. When using the service of a credit referencing agency we will pass them your personal details and details of your credit performance.
ICB are using Legitimate Interests (GDPR Article 6 (f)) as the legal basis for processing of your personal and credit information. These Legitimate Interests are promoting greater financial stability by supporting a full and accurate assessment of loan applications, aiding in the avoidance of over indebtedness, assisting in lowering the cost of credit, complying with and supporting compliance with legal and regulatory requirements, enabling more consistent, faster decision-making in the provision of credit and assisting in fraud prevention.
Please review ICB’s Fair Processing Notice which is available at http://www.icb.ie/pdf/Fair Processing Notice.pdf
It documents who they are, what they do, details of their Data Protection Officer, how they get the data, why they take it, what personal data they hold, what they do with it, how long they retain it, who they share it with, what entitles them to process the data (legitimate interests), what happens if your data is inaccurate and your rights i.e. right to information, right of access, right to complain, right to object, right to restrict, right to request erasure and right to request correction of your personal information.
Where you breach the loan agreement we may use the service of third parties to recover the debt. We use a private investigator in order to confirm addresses and serve legal notices in the event that you default on your loan agreement.
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
We carry out searches in Stubbs Gazette 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 credit history 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.
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.
• We will only carry out the below processing when we have obtained your consent and will cease processing once you withdraw such consent.
• We will only market goods and services to you where we have obtained your consent for same. Where you have consented to receiving marketing material you can withdraw your consent for this at any time by contacting Blackpool Credit Union.
• To help us improve and measure the quality of our products and services we undertake market research from time to time. This may include using the Irish League of Credit Unions and/or specialist market research companies. See section on Your Marketing Preferences below.
Your Marketing Preferences
As part of improving our service to you, from time to time, we would like to inform you of goods, services, competitions and/or promotional offers available from us. We may wish to use different means when sending such marketing communications.
Our member application forms now include confirmation to methods you consent to being contacted, if any, by ticking Yes to each method of communication below
Yes Post ☐ Email ☐ Text ☐ Signature of applicant Date:
You have a right to notify us free of charge at any time of your right to refuse such marketing by email to email@example.com or by using the ''opt-out" options in any marketing message we send you.
Your Rights in connection with your personal information are to:
• Find out whether we hold any of your personal data, if we do, get a request access to that data and then be furnished with a copy of that data. You are also entitled to request further information about the processing.
• Request correction of the personal information 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 information 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 information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. You can ask us to suspend processing personal information 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;
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 Data Protection Commissioner (DPC) in respect of any processing of your data by:
Telephone - +353 57 8684800 +353 (0)761 104 800
Lo Call Number - 1890 252 231
E-mail - firstname.lastname@example.org
Postal Address - Data Protection Commissioner
Canal House Station Road
Portarlington R32 AP23 Co. Laois
**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 email email@example.com
There is no fee in using any of your above rights, unless your request for access is clearly unfounded or excessive. Alternatively, we may 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 information 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 any of these above rights, please contact us at 021 450 1757 or firstname.lastname@example.org