We are committed to protecting our members’ privacy. The credit union requires any information marked as mandatory for membership to either meet legal obligations or to enable us to perform our contract with you.
Where you are not able to provide us with this information, we may not be able to open an account for you. Where we request further information about you not required for these reasons, we will ask you for your consent.
How we use your personal information
Castle & Crystal Credit Union may process, transfer and/or share personal information in the following ways:
For legal obligations
- to confirm your identity
- to perform activity for the prevention of money laundering and financial crime
- to carry out internal and external auditing
- to record basic information about you on a register of members
For performance of our contract with you
- to deal with your account(s) or run any other services we provide to you;
- to consider any applications made by you;
- to carry out credit checks and to obtain and provide credit references
- to undertake statistical analysis, to help evaluate the future needs of our members and to help manage our business
For legitimate interests
- to conduct activity for the purposes of debt recovery
With your consent
- to inform you of products and services by direct marketing (unless you specifically object to this), or to conduct market research.
- By joining the credit union you agree that we can send you statements, new terms & conditions, information about changes to the way your account(s) operate and notification of our Annual General Meeting.
Sharing your personal information
We will disclose information outside the credit union only:
- to third parties to help us confirm your identity to comply with anti-money laundering legislation
- to credit reference agencies and debt recovery agents who may check the information against other databases – private and public – to which they have access
- to any authorities if compelled to do so by law (e.g. to HM Revenue & Customs to fulfil tax compliance obligations)
- to fraud prevention agencies to help prevent crime or where we suspect fraud;
- to any persons, including, but not limited to, insurers, who provide a service or benefits to you or for us in connection with your account(s);
- To our suppliers in order for them to provide services to us and/or to you on our behalf
- to anyone in connection with a reorganisation or merger of the credit union’s business
- other parties for the administration of marketing communications (We will NEVER sell or share your information to other companies for marketing of products and services not provided by the credit union or in connection with your credit union account)
Where we send your information
While countries in the European Economic Area all ensure rigorous data protection laws, there are parts of the world that may not be quite so rigorous and do not provide the same quality of legal protection and rights when it comes to your personal information.
The credit union does not directly send information to any country outside of the European Economic Area, however, any party receiving personal data may also process, transfer and share it for the purposes set out above and in limited circumstances this may involve sending your information to countries where data protection laws do not provide the same level of data protection as the UK.
For example, when complying with international tax regulations we may be required to report personal information to the HM Revenue and Customs which may transfer than information to tax authorities in countries where you or a connected person may be tax resident.
Retaining your information
The credit union will need to hold your information for various lengths of time depending on what we use your data for. In many cases we will hold this information for a period of time after you have left the credit union.
For a copy of our policy for retaining members data please contact us at firstname.lastname@example.org or 01384 815771
Credit referencing agencies
In order to process credit applications you make we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.
We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates. This may affect your ability to get credit.
The identities of the CRAs, and the ways in which they use and share personal information, are explained in
more detail on:
- TransUnion at https://www.transunion.co.uk/crain
- Equifax at www.equifax.co.uk/crain
- Experian at www.experian.co.uk/crain
We may use automated decision making in processing your personal and financial information to make credit decisions.
It is our policy to manually review automated decisions whenever possible. However, you have the right to request a manual review of the accuracy of any decision we make if you are unhappy with it.
Castle & Crystal Credit Union Ltd uses a company called NestEgg Ltd to process this data on our behalf. NestEgg Ltd provides an automated ‘decision’ to help the Credit Union make it easy for members to apply for loans and savings accounts. NestEgg Ltd is not responsible for making decisions, they do not see your personal information. Their software makes a recommendation to a loans officer.
When you apply for a loan and / or savings account up to five searches may appear on your credit file. For the purposes of credit scoring, this will typically only affect your credit score as if one credit application were made.
Each of these five ‘footprints’ relate to the different sources of data being used to assess an application; these include the credit report itself and an affordability check. The Credit Union needs to prove the information belongs to you which is when an ID check is required. In cases where an application is made by a new member; the Credit Union will use an ID check and may also run a report to check ownership of any bank account details you may give us. These checks are required by law to prevent money laundering.
Some of these footprints will be in the name of NestEgg Ltd and others in the name of Castle & Crystal Credit Union Ltd.
Your Data Protection Rights
Your rights under data protection regulations are:
(a) The right to access
(b) The right of rectification
(c) The right to erasure
(d) The right to restrict processing
(e) The right to data portability
(f) The right to object to data processing
(g) Rights related to automating decision-making and profiling
(h) Right to withdraw consent
(i) The right to complain to the Information Commissioner’s Office
Your rights explained
Right to Access
You have the right to access your personal data and details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. Please contact the credit union for more information on how to exercise this right.
The right to rectification
You have the right to have any inaccurate personal data about you corrected and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
The right to erasure
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include:
- the personal data is no longer needed for the purpose it was originally processed
- you withdraw consent you previously provided to process the information
- you object to the processing under certain rules of data protection law
- the processing is for marketing purposes
- the personal data was unlawfully processed
However, you may not erase this data where we need it to meet a legal obligation or where it necessary for the establishment, exercise or defence of legal claims.
The right to restrict processing
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are:
- you contest the accuracy of the personal data;
- processing is unlawful but you oppose erasure;
- we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and
- you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data.
We will only otherwise process it:
- with your consent;
- for the establishment, exercise or defence of legal claims; or
- for the protection of the rights of another natural or legal person;
The right to object to processing
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the data is necessary for the purposes of the legitimate interests pursued by us or by a third party.
If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
The right to data portability
To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of our contract with you
You have the right to receive your personal data from us in a commonly used and machine-readable format or
instruct us to send this data to another organisation. This right does not apply where it would adversely affect
the rights and freedoms of others.
Rights related to automatic processing
This credit union may use automated processes for processing members’ loan or membership applications to make sure that our decisions are quick, fair, efficient, and correct based on what we know. If the credit union uses fully automated decision processes then you have the right to have the decision reviewed by a member of staff, express their point of view, and obtain an explanation of the decision and challenge it
Right to withdraw consent
To the extent that the legal basis for our processing of your personal information is your consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
The right to complain to the Information Commissioner’s Office
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the Information Commissioner’s Office which is responsible for data protection in the UK. You can contact them by:
Going to their website at: https://ico.org.uk
Phone on 0303 123 1113
Post to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
For more information about how your rights apply to your membership of the credit union or to make a request under your Subject Access Rights please contact us.