PRIVACY NOTICE
Credit Union Privacy Notice
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 for your consent.
How we use your personal information
WHEB Credit Union may process, transfer and /or share personal information in the following ways:
For legal reasons
Confirm your identity
Perform activity for the prevention of financial crime
Carry out internal and external auditing
Record information about you on a members’ register
For performance of our contract with you
Deal with your account or run any other services we provide to you
Consider any applications made by you
Carry out credit checks and to obtain credit references
Undertake statistical analysis, to help evaluate the future needs of our members and to help manage our business
To send you statements, new terms and conditions (including changes to this privacy statement), information about changes to the way your account operates and notifications of our Annual General Meeting
For our legitimate interests
Recovery of any debts owed to us*
With your consent
Maintain our relationship with you including marketing and market research (if you agree to them)
Sharing your personal information
We will disclose information outside the credit union:
To third parties to confirm your identity to comply 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. HMRC, 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 other members when they view the members’ register which contains details of members’ names, joining and leaving dates, and mailing addresses
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)
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 U.K.
For example, when complying with international tax regulations we may be required to report personal information to HMRC which may transfer that 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.
To read our policy for retaining data please see: www.whebcreditunion.com, or contact us at: 01698 307334
Credit rating agencies
In order to process credit applications you make, we may supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as 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.
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 ways in which CRAs, use and share personal information are explained in more detail and can be found on:
Equifax at www.equifax.co.uk/crain
Experian at www.experian.co.uk/crain
CallCredit at www.calldredit.co.uk/crain
Your rights
Your rights under data protection regulations are:
The right to access
The right to rectification
he 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
The right to withdraw consent
The right to complain to the Information Commissioner’s Office (ICO)
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.
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.
Your 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.
Rights related to automatic processing
This credit union does not, at present, use an automated decision making process for processing members’ loan applications. However, if this process is introduced at a later date your rights regarding this process will be added to this Privacy Notice.
Members have the right to have a decision made by this process, 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 a legal 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 (ICO)
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 (ICO) 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: admin@whebcreditunion.com or 01698 307334.
We will aim to respond to your request or query within one month or provide an explanation of the reason for our delay.
Contact details of credit union
WHEB Credit Union Ltd
13 Burnbank Centre
Burnbank
Hamilton
ML3 0NQ
01698 307334
Changes to this privacy policy
We can update this Privacy Policy at any time and ideally you should check it regularly here: www.whebcreditunion.com 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.