CREDIT UNION

BLSCU Privacy Notice

Bridgend Lifesavers Credit Union Privacy Notice

This notice provides information about how Bridgend Lifesavers Credit Union (“Credit Union”) collects, processes and shares your personal data.

For the purposes of the applicable data protection law including the Data Protection Act 1998 and, from its entry into force on 25 May 2018 the General Data Protection Regulation (Regulation (EU) 2016/679) (“Data Protection Law”), Bridgend Lifesavers Credit Union, Community Hub, Merfield Close, Sarn, CF32 9SW is the Data Processor and Data Controller of the information it collects from you.  

Should you have any queries or require further information please contact General Manager Nicola Field on  01656 729912/ 01656 667089, info@blscu.co.uk or by post using the address above

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

Bridgend LifeSavers Credit Union may process, transfer and/or share personal information in the following ways:

1.1 for legal reasons:

to confirm your identity
to perform activity for the prevention of financial crime
to carry out internal and external auditing
to record basic information about you on a register of members

1.2 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

1.3 with your consent:

to maintain our relationship with you including marketing and market research (if you agree to them)

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 of the credit union only:

to third parties to help us confirm your identity, in compliance with 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
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 marketing purposes (if you agree to this)

2.1 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 that information to tax authorities in countries where you or a connected person may be tax resident.

2.2 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.
To read our policy for retaining members data please see our Data Retention Policy or contact us at: 01656 729912 or info@blscu.co.uk

2.3 Credit Rating 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: 

CallCredit at www.callcredit.co.uk/crain
Equifax at www.equifax.co.uk/crain
Experian at www.experian.co.uk/crain
Or by contacting us via email info@blscu.co.uk or by telephone 01656 729912

Your Rights

Your rights under data protection regulations are:

The right to access
The right of rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object to data processing
Rights related to automating decision-making and profiling
Right to withdraw consent
The right to complain to the Information Commissioner’s Office

 Please see our website here www.blscu.co.uk

 3.1 Your rights explained

 3.1.1 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.

3.1.2 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.

3.1.3 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.

3.1.4 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; 

3.1.5 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.

 3.1.6 The Right to Data Portability

To the extent that the legal basis for our processing of your personal data is:

 consent; or

 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.

3.1.7 Rights Related to Automatic Processing

Bridgend LifeSavers Credit Union uses an automated decision making process for processing members’ loan applications to propose decisions to the loans team to enable quick, fair, efficient, and correct based decisions on what we know.

The automated lending decision system looks at your Experian credit score alongside information such as:

the amount applied for
Monies held in credit union share account
your income and expenditure
your history of repaying debts
the number and value of County Court Judgements (CCJs) you have
the number of accounts you have that are in default
public information such as the insolvency service
whether or not you are bankrupt
your age 

and makes a proposed decision based on either: 

Set policies e.g. the credit union does not lend to those less than 18 years of age, or the credit union does not lend to people with outstanding CCJs where no agreements are in place.
The predicted likelihood of the repayment of the loan based on the statistical analysis of whether individuals who had a similar credit profile repaid their debts in the past.

Proposed automated decisions are reviewed by members of staff, and members can appeal a decision, and have the right to an explanation.

3.1.8 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.

 3.1.9 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 

Contact us About your Rights

For more information about how your rights apply to your membership of the credit union or to make a request under your rights you can contact us at info@blscu.co.uk or on 01656 729912. We will aim to respond to your request or query within one month or provide an explanation of the reason for our delay.

4.1 Contact Details of Bridgend LifeSavers Credit Union

Bridgend LifeSavers Credit Union
The Lifelong Learning Centre
Merfield Close
Sarn
Bridgend
CF32 9SW

4.2 Changes to this Privacy Policy

We can update this Privacy Policy at any time and ideally you should check it regularly here www.blscu.co.uk for updates. We won’t alert you for every small change, but if there are any important changes to the Policy or how we use your information we will let you know and where appropriate ask for your consent.

Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Registration No: 213681