Privacy Policy

PRIVACY – how we use your personal information

This Privacy Notice is to let you know how Harlowsave Credit Union Limited (HSCU) promises to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a member, and the choices you give us about what marketing you want us to send to you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.

Our Privacy Promise
We promise:

• To keep your data safe and private
• Not to sell your data
• To give you the ways to manage and review your marketing choices at any time

How the law protects you
As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.
Data Protection Law says that we are allowed to use personal information only if we have a proper reason to do so. The law says we must have one or more of these reasons:

• To fulfil a contract we have with you, or
• When it is our legal duty, or
• When it is in our legitimate interest, or
• When you consent to it

A legitimate interest is when we have a business or commercial reason to use your information. 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.
Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

What we use your personal information for Our reasons Our legitimate interest
To manage our relationship with you or your business Your consent Keeping our records up to date
To develop new ways to meet our member needs and to grow our business Fulfilling contracts Working out which of our products and services may interest you and telling you about them
To develop and carry out marketing activities
To study how our members use our products and services Our legal duty Seeking your consent when we need to contact you
To provide advice and guidance about our products and services Being efficient about how we fulfil our legal duties
To develop and manage our products and services Fulfilling contracts Developing products and services
To test new products Our legitimate interests Being efficient about how we fulfil our legal duties
To manage how we work with other companies that provide services to us and our members Our legal duty
To collect and recover money that is owed
To detect, investigate, report and seek to prevent financial crime Fulfilling contracts Developing and improving how we deal with financial crime, in addition to our legal duties in this respect.
To obey laws and regulations that apply to us Our legal duty Being efficient about how we fulfil our legal and contractual duties
To respond to complaints and seek to resolve them
To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance and audit. Our legitimate interests
and Our legal duty
Complying with regulations that apply to us and
being efficient about how we fulfil our legal and contractual duties
To exercise our rights set out in agreements and contracts Fulfilling contracts

Groups of Personal Information

We may use many different kinds of personal information and group them together like this.
Financial Your financial position, status and history
Contact Where you live and how to contact you
Socio-Demographic This may include details about your work or profession and nationality
Transactional Details about your payments to and from your accounts with
Contractual Details of products and services we provide to you
Locational Data we get about where you are, such as may come from your mobile phone, or the address where you connect a computer to the internet.
Behavioural Details about how you use our products and services.
Technical Details on the devices and technology you use
Communications What we learn about you from letters, emails and conversations between us.
Social Relationships Your family, friends and other relationships
Open Data and Public Records Details about you that are in public records such as the Electoral Register and information about you that is openly available on the internet
Usage Data Other data about how you use our products and services
Documentary data Details about you that are stored in documents in different formats or copies of them. This could include things like your passport, driving licence or birth certificate.
Special types of data The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:
Racial or ethnic origin
Heath data, including gender
Criminal convictions and offences
Consents Any permissions, consents or preferences that you give us. This includes things like how you want us to contact you and whether you prefer your correspondence in large print format.
National Identifier A number or code given to you by a government department to identify who you are, such as a National Insurance Number

Where we collect personal information from
We may collect personal information about you (or your business) from these sources:

• When you apply for your products and services
• When you talk to us on the phone or in one of our branches
• When you use our website
• In emails and letters
• In financial reviews and interviews
• In member surveys
• If you take part in competitions or promotions
• Social media posts when you interact with us

Data we collect when you use our services include the amount, frequency, type, location, origin and recipients:

• Payment and transaction data
• Profile and usage data. This includes the profile you create to identify yourself when you connect to our online banking. It also includes other data about how you use those services. We gather this data from the devices you use to connect to those services such as computers and mobile phones.

Data from third parties we work with:-

• Your employer where you choose to save or repay a loan via payroll deduction
• Prepaid card company
• Credit reference agencies
• Social networks
• Fraud prevention agencies
• Public information such as companies house
• Government and law enforcement agencies
• Medical Practitioners

Who we share your personal information with
We may share your personal information with:

• Agents and advisers who we use to help run your accounts and services, collect what you owe and explore new ways of doing business with you
• H M Revenue and Customs, regulators and other authorities
• UK Financial Services Compensation Scheme
• Credit reference agencies
• Fraud prevention agencies
• Companies that we introduce you to
• Companies you ask us to share your data with
• Cuna Mutual Insurance or any such insurance company that provides Loan Protection and Life Savings Insurance on our behalf
• Your employer where you choose to save or repay a loan via payroll deduction
• We may need to share your personal information with other organisations to provide you with a product or service you have chosen:
• If you have a prepaid debit card through our chosen provider
• We may also share your personal information if the make-up of UCUL changes in the future:
• We may choose to transfer or merge the business or we may seek to acquire other business to merge with
• During any such process we may share your data with other parties. We will only do this if they agree to keep your data safe and private
• If the change to UCUL happens, other parties may use your data in the same way as set out in this notice

How we use your information to make automated decisions
We sometimes use systems to make automated decisions based on personal information we have, or are allowed to collect from others about you or your business. This helps us to make sure our decisions are quick, fair, efficient and correct based on what we know.
Opening Accounts
When you open an account with us, we check that the product and service is relevant for you based on what we know. We also check that you or your business meets the conditions needed to open the account. This may include checking age, residency, nationality or financial position.

Approving Credit
We use a system to decide whether to lend money to you when you apply for a loan. This uses past data to assess how you’re likely to act while paying back any money you borrow. This includes data about similar accounts you may have had before and data from four sources:

• Your application form
• Credit reference agencies
• Data we may already hold
• Your bank/building society or post office statement(s)

This gives us an overall assessment and helps us to make responsible lending decisions that are fair and informed.

Your rights
As a person you have rights over automated decisions.

• You can ask that we do not make our decision based on the automated score alone
• You can object to an automated decision and ask that a person reviews it

If you want to know more about these rights please contact us.

Credit Reference Agencies
We carry out credit and identity checks when you apply for a product or service for you or your business and use Credit Reference Agencies to help with this. If you use our services from time to time, we may also search information that the credit reference agencies have to help us manage the accounts.
We will share your information with credit reference agencies and they will give us information about you. The data we exchange can include:

• Name, address and date of birth
• Credit application
• Financial situation and history
• Public information from sources such as the Electoral Register and Companies House

We will use this data to:

• Assess whether you are able to afford to make repayments
• Ensure you have provided accurate information
• Help to detect and prevent financial crime
• Manage accounts with us
• Trace and recover debts

We will go on sharing your personal information with credit reference agencies for as long as you are a member. This will include details about your settled accounts and any debts not fully repaid on time. If you borrow, it will include details of your repayments and whether you repay in full and on time. The credit reference agencies may give this information to other organisations that want to check your credit status. We will also tell the credit reference agencies when you settle your accounts with us.

When we ask credit reference agencies about you, they will note it on your credit file. This is called a credit search. Other lenders may see this and we may see credit searches from other lenders. You can find out more about the credit reference agencies on their websites. This includes details about:

• Who they are
• Their role as fraud prevention agencies
• The data they hold and how they use it
• How they share personal information
• How long they can keep the data
• Your data protection rights

We may need to confirm your identity before we provide products and services to you or your business. Once you have become a member of ours, we will share your personal information as needed to help detect fraud and money laundering risks. We use Fraud Prevention Agencies to help us with this.   Both UCUL and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law or for a ‘legitimate interest’. A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for you. We will use the information to:

• Confirm identity
• Help prevent fraud and money-laundering
• Fulfil any contracts you or your business have with us

We or a fraud prevention agency may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate and prosecute crime.
Fraud prevention agencies can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.
These are some of the kinds of personal information that we use:

• Name
• Date of birth
• Residential address
• History of where you have lived
• Contact details, such as email address and phone number
• Financial data
• Employment details
• Data that identifies computers or other devices you use to connect to the internet. This includes your IP address

Fraud Prevention
The information we have for you or your business is made up of what you tell us and data we collect when you use our services or from third parties we work with.
We and fraud prevention agencies may process your personal information in systems that look for fraud by studying patterns in data. We may find that an account is being used in ways that fraudsters work or we may notice that an account is being used in a way that is unusual for you or your business. Either of these could indicate a possible risk of fraud or money-laundering.
How this can affect you
If we or a fraud prevention agency decide there is a risk of fraud, we may stop activity on the accounts or block access to them. Fraud prevention agencies may also keep a record of the risk that you or your business may pose. This may result in other organisations refusing to provide you with products or services or to employ you.

Data transfers out of the EEA
Fraud prevention agencies may send personal information to countries outside of the European Economic Area (EEA). When they do there will be a contract in place to ensure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.

Sending data outside of the EEA
We will only send data outside of the EEA to:

• Follow your instructions
• Comply with legal duty
• Work with agents and advisers who we use to help run your accounts and services
• If we transfer information to our agents or advisers outside of the EEA, we will ensure that it is protected in the same way as if it was being used in the EEA. We will use one of these safeguards:
• Transfer it to a non EEA country with privacy laws that give you the same protection as the EEA
• Put in place a contract with the recipient that means they must protect it to the same standards as the EEA
• Transfer it to organisations that are part of a Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It ensure the standards are similar to what is used within the EEA.

If you choose not to give personal information
We may need to collect personal information by law, or under the terms of a contract we have with you. If you choose not to give this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your account with us. It could mean that we cancel a product or service you have with us. Any data collection that is optional will be made clear at the point of collection.

Marketing
We may use your personal information to tell you about relevant products or services. This is what we mean when we talk about marketing. The personal information we have for you is made up of what you tell us and data we collect when you use our services, or from third parties we work with. We study this to form a view of what we think you may want or need, or what may be of interest to you. This is how we decide which products or services may be relevant for you.
We can only use your personal information to send you marketing messages if we have either your consent or a legitimate interest. This is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.
You can ask us to stop sending you marketing messages at any time by contacting us.
Whatever you choose, you will still receive statements and other important information such as changes to your products and services and information as a member of UCUL, such as AGM or SGM notices.
We may ask you to update or confirm your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulations or structure of our business. If you change your mind you can update your choices by contacting us at any time.

How long we keep your personal information
We will keep your personal information for as long as you are a member of Harlowsave Credit Union Limited. After you stop being a member, we may keep your data for up to 6 years for one of these reasons:

• To respond to any questions or complaints
• To show that we treated you fairly
• To maintain records according to rules that apply to us

We may keep your data for longer than 6 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do we will ensure that your privacy is protected and only use it for those purposes.
How to get a copy of your personal information
You can access your personal information by completing a Subject Access Request Form available on request from any of our branches or you can request this online by emailing admin@harlowsave.coop.
Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think is wrong of incomplete. Please contact us if you wish to do this. If you do, we will take all reasonable steps to check the accuracy and correct it where necessary.
What if you want us to stop using your personal information?
You have the right to object to our use of your personal information, or to ask us to delete, remove or stop using your personal information if there is no need for us to retain it. This is known as the ‘right to object’ and ‘right to erasure’ or ‘right to be forgotten’.
There may be a legal or other official reason why we need to keep or use your data but please tell us if you think we should not be using it.
We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things such as legal claims to exercise a legal right. In this situation we would not share or use your data in other ways whilst it is restricted.
You can ask us to restrict the use of your personal information if:

• It is not accurate
• It has been used unlawfully but you don’t want us to delete it
• It is not relevant any more but you want us to keep it for use in legal claims
• You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to continue using it

If you want to object to how we use your date, or ask us to delete it or restrict how we use it, please contact us.

How to withdraw your consent
You can withdraw your consent at any time. Please contact us if you wish to do so. If you withdraw your consent we may not be able to provide certain products or services to you. If this is the case, we will tell you.

How to complain
Please let us know if you are unhappy with how we have used your personal information. Please call into your local branch and speak to one of our team or email admin@harlowsave.coop Alternatively you can write to the Complaints Officer, Harlowsave Credit Union Limited, Harlowsave Credit Union
First floor, The Central Library Harlow, Essex CM20 1HA.
United KingdomYou also have the right to complain to the Information Commissioner’s Office. Find out more on their website https://ico.org.uk/
Data Privacy Laws will change on 25th May 2018. From this date you have the right to get your personal information from us in a format that can easily be re-used. You can also ask us to pass on your personal information in this format to other organisations.

Harlowsave Credit Union
The Central Library,
First floor (lift available)
Harlow
CM20 1HA

Telephone: 01279 451234

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