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
Central Liverpool 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 and 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 [email protected] or 0151 708 5515
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 at:
- Transunion at www.transunion.co.uk/crain
- Equifax at www.equifax.co.uk/crain
- Experian at www.experian.co.uk/crain
They may retain information for up to 6 years after any credit agreement between us has ended. When we share this information all parties conform to industry standards.
When we check your account this leaves a footprint on your credit file.
Central Liverpool 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 Central Liverpool 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
Prize Draw - Privacy Notice
Last Updated: 14 October 2019 2019.
This Privacy Notice describes how Central Liverpool Credit Union HM Treasury (together, "we", "us") collect and process personal information of PrizeSaver Account Customers in relation to the Prize Draw scheme (the "Prize Draw").
Controller of personal information
Central Liverpool Credit Union whose registered office is at 141 Park Street, Liverpool L8 6QF and HM Treasury whose address is at 1 Horse Guards Road, London SW1A 2HQ are both data controllers of personal information collected and processed in relation to the Prize Draw.
What personal information do we collect?
Here are the types of information we collect about you in order to provide the Prize Draws, to provide marketing about the Prize Draws and to evaluate the effectiveness of the Prize Draws:
- your name and contact information, including your email address and telephone number;
- information about your PrizeSaver account. This includes information about the accounts you hold with Central Liverpool Credit Union the transactions on your account and the balance of your account;
- socio-demographic information (such as income, savings levels etc) which we review on an anonymised basis; and
- any information you provide about how you were made aware of the PrizeSaver account.
For what purposes do we process personal information?
We process personal information for the following purposes:
- Eligibility. We use your personal information to consider your eligibility for a Prize Draw, to award a winner and to facilitate the payment of Prizes.
- Communicate with you. We use personal information to communicate with you in relation to the Prize Draws.
- To deal with your enquiries and requests.
- For marketing purposes. We use personal information to develop, manage and conduct advertising and marketing campaigns, promotions and offers.
- Evaluation of the Prize Draws. We will also use personal information to evaluate the success and effective operation of the Prize Draws. HM Treasury may contact you directly for the purpose of conducting an evaluation of the Prize Draws.
- Fraud Prevention and AML checks. We process personal information to prevent and detect fraud and to run anti-money laundering checks so as to ensure that Prizes are not awarded to individuals who have made fraudulent entries or do not comply with our anti-money laundering checks.
- Comply with legal obligations. In certain cases, we have a legal obligation to collect and process personal information.
We must have a lawful basis to process personal information, which in most cases will be one of the following:
- to fulfil Central Liverpool Credit Union’s contractual obligations to you, including to operate and provide the Prize Draw;
- to comply with the respective legal obligations of Central Liverpool Credit Union and HM Treasury, for example, obtaining proof of your identity to enable us to meet our anti-money laundering obligations;
- in relation to data processing by HM Treasury, to perform a specific task in the public interest that is set out in law;
- we may obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to Central Liverpool Credit Union direct marketing activities). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice; or
- to meet the legitimate interests of Central Liverpool Credit Union and HM Treasury, for example to understand how you use your PrizeSaver account and to enable us to derive knowledge from that to enable us to develop new products and services.
Where we rely on our legitimate business interests, we have undertaken an assessment where we have balanced individuals' rights against ours to ensure that our interest is not overridden by the interests individuals have to protect personal information.
We may share personal information for certain purposes and with the entities described in this section:
- Service providers: We will share personal information with our service providers to perform functions on our behalf, including carrying out the Prize Draw, performing marketing services, evaluating the Prize Draw scheme and any other business operations for us.
- Business transfers: We may share personal information to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.
- As required by law: We may share personal information to law enforcement agencies, courts, regulators, government authorities or other third parties. We may share personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
Transfers out of the European Economic Area
Whenever we transfer personal information to countries outside of the European Economic Area in the course of sharing information as set out above, we will put in place appropriate safeguards (such as standard contractual clauses) in accordance with applicable laws on data protection. For more information on the appropriate safeguards in place or to obtain a copy, please contact us using the contact information below.
What rights do I have?
Subject to applicable law, you have the following rights
- to request information about how your personal information is processed and to request a copy of the personal information;
- to request that any inaccuracies in your personal information are rectified;
- to request that your personal information is deleted;
- in certain circumstances, to request that the processing of your personal information is restricted;
- to object to the processing of your personal information; and
- to data portability, which allows your data to be copied or transferred from one IT environment to another.
If you wish to do any of these things, please contact Central Liverpool Credit Union at https://centralcu.co.uk/contact-us/
How long do we keep personal information?
We will keep your personal information for as long as we have a relationship with you and for a period of time thereafter to enable us to:
- maintain business records for analysis and/or audit purposes;
- comply with record retention requirements under the law;
- defend or bring any existing or potential legal claims;
- deal with any complaints regarding the services; and
- any other purposes for which personal information will be retained.
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
Contacts, notices and revisions
If you have any questions about this Privacy Notice, please contact us, Central Liverpool Credit Union at https://centralcu.co.uk/contact-us/ We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the Information Commissioner's Office using their website www.ico.co.uk or with a local authority.
We may modify or update this Privacy Notice from time to time. Where changes to this Privacy Notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on individuals, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).
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 contact us.