Privacy Notice

Your information will be held by No1 CopperPot Credit Union. This Privacy Notice explains how we look after your personal information in compliance with the relevant Data Protection Regulation and laws. 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 you. This notice also 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 ways to manage and review your marketing choices at any time.

 

Who We Are

No1 CopperPot Credit Union. This section gives you the legal name of our company who holds your personal information – known as the ‘legal entity’ – and tells you how you can get in touch with us.

No1 CopperPot Credit Union’s registered office is at Slater House, Oakfield Road, Cheadle Royal Business Park, Cheadle, Cheshire SK8 3GX and we are a company registered in England and Wales under company number IP000078. Our registered name is Number One Police Credit Union Limited, but we trade as No1 CopperPot Credit Union. We are registered on the Information Commissioner’s Office Register; registration number Z7902893, and act as the data controller when processing your data. We can be contacted at Slater House, Oakfield Road, Cheadle Royal Business Park, Cheadle, Cheshire SK8 3GX. Telephone 0161 741 3160, or email info@no1copperpot.com.

 

Information That We Collect

This explains what all the different types of personal information mean, that are covered by data protection law. No1 CopperPot Credit Union processes your personal information to meet our legal, statutory, and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice.

We use various kinds of personal information. They are grouped together in the below table. The groups are all listed here so that you can see what we may know about you. We do not use all this data in the same way. Some of it is useful for marketing, or for providing services to you. But some of it is private and sensitive and we treat it that way.

 

Type of Personal Information Description
Financial Your financial position, status, and history
Contact Your name, where you live, and how to contact you
Socio-Demographic This includes details about your work or profession, nationality and where you fit into general social or income groupings
 Transactional Details about payments to and from your accounts with us
Contractual Details about the products or services we provide to you
Locational Data we get about where you are. This may come from your mobile phone, or the place where you connect a computer to the internet
Behavioural Details about how you use products and services from us and other organisations, this may come from bank statements
Technical Details on the devices and technology you use
Communications What we learn about you from letters and emails you write to us, and conversations between us
Social Relationships Your family 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, driver’s license, or birth certificate
Special Categories of Data The law and other regulations treat some types of personal information as special. We will only collect and use these if the law allows us to do so:

  • Racial or ethnic origin
  • Religious, political, or philosophical beliefs
  • Trade union membership
  • Genetic and bio-metric data
  • Lifestyle information, including data related to sex life or sexual orientation
  • Health data
  • Criminal records of convictions and offences
  • Allegations of criminal offences

You can read how we may use special types of data in the table ‘How we use your Personal Data’

Consents Any permissions, consents, or preferences that you give us. This includes things like how you want us to contact you or prefer large-print formats

 

Where We Collect Personal Information From

This section lists all the places where we get data that counts as part of your personal information. We may collect personal information about you from any of these sources:

Data you give to us:

This covers data given by you as well as data provided by people linked with your product or service, or people working on your behalf. This could mean a joint account holder, trustee, or a department of the Police Force.

  • When you apply for our products and services
  • When you talk to us on the phone or in person, including recorded calls and notes we make
  • When you use our website and web chat
  • In emails and letters
  • In financial reviews and interviews
  • In customer surveys
  • If you take part in our competitions or promotions.

 

Data we collect when you use our services.

This covers two things: details about how and where you access our services, and account activity that is shown on your statement.

This includes the amount, frequency, type, location, origin, and recipients:

  • Payment and transaction data (we do not store card details)
  • Profile and usage data. This includes the profile you create to identify yourself when you connect to our internet, mobile and telephone services. It also includes other data about how you use those services, e.g. time and frequency. We gather this data from devices you use to connect to those services, such as computers, mobile phones, and by using cookies.

 

Data from outside organisations:

  • Credit reference agencies (e.g. Equifax)
  • Fraud prevention agencies
  • Payroll service providers
  • Public information sources such as the Financial Conduct Authority
  • Government and law enforcement agencies
  • Firms providing data services (we receive reports, such as open banking reports, that we use to better understand our customers and look for general patterns and trends)
  • Other financial services companies (to fulfil a payment or other service as part of a contract with you, or to help prevent, detect, and prosecute unlawful acts and fraudulent behaviour)
  • Land agents (such as firms who do property valuations for mortgages)
  • Social networks and other technology providers (for instance, when you click on one of our Facebook or Google ads)
  • Employers (for instance, to get a reference if you apply for a mortgage)
  • Public information sources such as the Electoral Register or Companies House
  • Agents, suppliers, sub-contractors, and advisers

 

How We Use Your Personal Data

Data Protection law states that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside No1 CopperPot Credit Union. 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, or
  • When it is in the public interest.

When we have a business or commercial reason of our own to use your information, this is called a ‘legitimate interest’. We will tell you what that is, if we are going to rely on it as the reason for using your data. Even then, it must not unfairly go against your interests.

The law and other regulations treat some types of sensitive personal information as special. This includes information about racial or ethnic origin, sexual orientation, religious beliefs, trade union membership, health data, and criminal records. We will not collect or use these types of data without your consent unless the law allows us to do so. If we do, it will only be when it is necessary:

  • For reasons of substantial public interest, or
  • To establish, exercise or defend legal claims.]

No1 CopperPot Credit Union takes your privacy very seriously and will never disclose, share, or sell your data without your consent, unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have given consent for us to share information about our products and services, this can be withdrawn at any time.

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 information for Our reasons Our legitimate interests
Serving you as a member
  • To manage our relationship with you
  • To develop new ways to meet your needs
  • To develop and carry out marketing activities
  • To develop and manage our products and services
  • To communicate with you about our products and services
  • Your membership
  • Your consent
  • Fulfilling contracts
  • Our legal duty
  • Keeping our records up to date
  • Telling you about our products and services
  • Developing products and services be this existing or new
  • Seeking your consent when we need it to contact you
  • Being efficient about how we fulfil our legal and contractual duties
Managing our operations
  • To deliver our products and services
  • To make and manage customer payments
  • To manage fees, charges and interest due on accounts
  • To collect and recover money that is owed to us
  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty
  • Being efficient about how we fulfil our legal and contractual duties
  • Complying with rules and regulations that apply to us
Managing security, risk and crime prevention
  • To detect, investigate, report, and seek to prevent financial crime
  • To manage risk for us and our members
  • To obey laws and regulations that apply to us
  • To respond to complaints and to seek to resolve them
  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty
  • Developing and improving how we deal with financial crime, as well as fulfilling our legal duties
  • Complying with regulations that apply to us
  • Being efficient about how we fulfil our legal and contractual duties
Business Management
  • To run our credit union in an efficient and proper way.  This includes managing our financial position, business capability, planning, adding and testing systems and processes, communications, corporate governance and audit
  • To exercise our rights set out in agreements or contracts
  • Our legitimate interests
  • Our legal duty
  • Fulfilling contracts
  • Complying with regulations that apply to us
  • Being efficient about how we fulfil our legal duties
  • Both parties delivering on their contractual obligations
Business Improvement
  • To test new products
  • To manage how we work with other companies that provide services to us and our customers
  • To develop new ways to meet our members needs and to grow our business
  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty
  • Developing products and services
  • Defining types of customers for new products or services
  • Being efficient about how we fulfil our legal and contractual duties

 

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. No1 CopperPot Credit Union uses third-parties, as covered within the data from outside organisations section; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this Privacy Notice, the data protection laws and any other appropriate confidentiality and security measures.


Credit Reference Agencies (CRAs)

We may carry out credit and identity checks on you when you apply for a product or service and may use Credit Reference Agencies to help us with this. If you use our services, we may also use the CRA information to help us manage your accounts. We will confirm that such agencies comply with the Data Protection Regulations in force at the time, be they inside or outside the EEA, and will ensure they are compliant with the Credit Reference Agency Information Notice (CRAIN).

The CRAIN agreement has been adopted by the three main credit reference agencies and describes how your personal data is used and shared in credit activity. You can view the CRAIN agreement by following any of these links: Equifax www.equifax.co.uk/crain; TransUnion www.transunion.co.uk/crain; Experian www.experian.co.uk/crain.

We will share your personal information with CRAs and they will give us information about you. The data we exchange can include:

  • Name, address, and date of birth
  • Credit application
  • Details of any shared credit
  • Financial situation and history
  • Public information, from sources such as the electoral register and Companies House.

We will use this data to:

  • Help us to assess whether you can afford to make repayments
  • Make sure what you have told us is true and correct
  • Help detect and prevent financial crime
  • Manage accounts with us
  • Trace and recover debts
  • Make sure that we tell you about relevant offers.

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

When we ask CRAs 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.

If you apply for a product with someone else, we will link your records with theirs. We will do the same if you tell us you have a spouse, partner, or civil partner.

You should tell them about this before you apply for a product or service. It is important that they know your records will be linked together, and that credit searches may be made on them.

CRAs will also link your records together. These links will stay on your files unless one of you asks the CRAs to break the link. You will normally need to give proof that you no longer have a financial link with each other.

You can find out more about the CRAs on their websites, in the Credit Reference Agency Information Notice. 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 data
  • Your data protection rights.

Here are the links to the agencies that we use.

  • Fraud Prevention Agencies – Trust ID www.trustid.co.uk/privacy-policy
  • Credit Reference Agencies – Equifax www.equifax.co.uk/crain
  • Experian – www.experian.co.uk/crain
  • Credit Kudos – www.creditkudos.com

 

Audit Purposes and Regulators

We may share your data with external auditors, this is a legal requirement and is the basis we would process your information in this case. Your data may also be shared with internal auditors and regulators. We are required by the Prudential Regulation Authority (PRA) to have an internal audit function (whether internal or external to the Credit Union). The regulators can also request information which we must provide. This is therefore done on a legal basis to ensure we meet our regulatory requirements.

 

Recording Phone Calls

We may monitor or record phone calls with you in order to check we have carried out your instructions correctly, to resolve queries or issues, for regulatory purposes, to help improve our quality of service, and to help detect or prevent fraud or other crimes. Conversations may be recorded for staff training purposes.

 

Fraud Prevention Agencies (FPAs)

We will need to confirm your identity before we provide products or services to you. Once you have become a member, we will also 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 ourselves and fraud prevention agencies can only use your personal information if we have a valid reason to do so. It must be needed 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 identities
  • Help prevent fraud and money-laundering
  • Fulfil any contracts you have with us.

We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent, and prosecute crime. FPAs 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 types of personal information that we use:

  • Name
  • Date of birth
  • Residential address
  • History of where you have lived
  • Contact details, such as email addresses and phone numbers
  • Financial data
  • Data relating to your products or services
  • Employment details
  • Data that identifies computers or other devices you use to connect to the internet. This includes your Internet Protocol (IP) address. Automated decisions for fraud prevention The 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 and FPAs may process your personal information in systems that look for fraud by studying patterns in the 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 an FPA decide there is a risk of fraud, we may stop activity on the accounts or block access to them. FPAs will also keep a record of the risk that you may pose.

This may result in other organisations refusing to provide you with products or services, or to employ you.

  • Fraud Prevention Agencies – Trust ID www.trustid.co.uk
  • Credit Reference Agencies – Equifax www.equifax.co.uk/crain

 

Intercom live web chat providers

As we use web chat, via https://www.intercom.com/live-chat, the providers do have access to limited personal information. The information which they can view and hold if you are signed into your account is your name, email address, type of device being used and a generalised area from which you are making contact. If you are not signed into your account, they can view the same information with the exception of your name and email address.

Intercom will automatically expire data on visitors that have not been seen in 9 months, to ensure they comply with GDPR retention requirements. They have a dedicated Data Protection Officer to oversee and advise on their data management. You can contact them by emailing compliance@intercom.com.

 

Your Rights

You have the right to access any personal information that No1 CopperPot Credit Union processes about you and to request information about:

  • What personal data we hold about you
  • The purposes of the processing
  • The categories of personal data concerned
  • The recipients to whom the personal data has/will be disclosed
  • How long we intend to store your personal data for
  • If we did not collect the data directly from you, information about the source.

You can object to us keeping or using your personal information. This is known as the ‘right to object’.

You can ask us to restrict the use of your personal information if:

  • It is not accurate
  • It has been used unlawfully but you do not want us to delete it
  • It is not relevant anymore, 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 keep on using it
  • If we do restrict your information in this way, we will not use or share it in other ways while it is restricted.

You can also ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to erasure’ or the ‘right to be forgotten’. You also have the right to object to any direct marketing from us. Where applicable, you have the right to data portability of your information and the right to be informed about any automated decision-making we may use.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information. We will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.

If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.

 

Safeguarding Measures

No1 CopperPot Credit Union takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure or destruction and have several layers of security measures in place, including: – SSL, TLS, encryptions, restricted access, IT authentication, firewalls, anti-virus/malware. Sensitive Data, in relation to you, has no special forms of encryption. It is protected in the same way as all other data as described above.

 

Transfers Outside The EU

Personal data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data.

No1 CopperPot Credit Union may utilise some services which are hosted outside the European Economic Area (EEA) and this may include your personal information. The companies we use, and the purpose of the processing is listed below:

Marketing MailChimp USA
SurveyMonkey USA
Identification Services Trust ID UK
Equifax USA
Financial Background Check Equifax USA

For those companies based outside the European Economic Area (“EEA”) we will ensure they are compliant with the General Data Protection Regulations.  You can find the privacy agreements here:

Equifax                        www.equifax.co.uk/crain

Trust ID                       www.trustid.co.uk/privacy-policy

Mailchimp                   www.mailchimp.com/legal/privacy

SurveyMonkey            www.surveymonkey.com/mp/legal/privacy-policy

When we send you an informational or marketing email, your e-mail information may be stored on servers which are hosted outside the EEA. Where this is the case, we will take steps to ensure that those providers use the necessary level of protection for your information and abide by strict agreements and measures set out by No1 CopperPot Credit Union to protect your data and comply with the relevant data protection laws.

 

Consequences of Not Providing Your Data

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 us 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 accounts or policies. It could mean that we cancel a product or service you have with us.

Any data collection that is optional would be made clear at the point of collection.

 

Marketing

We use marketing to let you know about products, services, and offers that you may want from us. This section tells you how we decide what marketing to show or send you. It also explains how we work out what you may be interested in.

We may use your personal information to make decisions about what products, services and offers we think you may be interested in. This is what we mean when we talk about ‘marketing’.

We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not conflict unfairly with your own interests.

The personal information we have for you is made up of what you tell us, and data we collect when you use our services. We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. This is called profiling for marketing purposes. You can contact us at any time and ask us to stop using your personal information this way.

If you allow it, we may show or send you marketing material online (on our own and other websites including social media), or by email, or post, or by text message.

What you get will depend on marketing choices that you set. You can change these at any time and tell us to stop sending you marketing.

Whatever you choose, you will still receive statements and other important information such as changes to your existing products and services.

We do not sell the personal information we have about you to outside organisations. We may ask you to confirm or update 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, regulation, or the structure of our business.

If you change your mind you can contact us to update your choices at any time.

 

How Long We Keep Your Data

No1 CopperPot Credit Union only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We will keep your personal information for as long as you are a member of the Credit Union.

After you stop being a member, we may keep your data for up to 10 years for one of these reasons:

  • To respond to any questions or complaints
  • To show that we treated you fairly
  • To study customer data as part of our own internal research
  • To obey rules that apply to us about keeping records. For example, the Money Laundering Regulations require us to retain certain data for a minimum of 5 and a maximum of 10 years
  • We may also keep your data for longer than 10 years if we cannot delete it for legal, regulatory, or technical reasons. If we do, we will make sure that your privacy is protected and only use it for those purposes.

Information relating to a defaulted account will be retained indefinitely. The reason for this is; you will still be classed as a member of the Credit Union and we may use this information to make future decisions on any accounts you may wish to change or open.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent. Details of the data we hold and the length of time we will keep such data can be found at Appendix 1.

 

How to Get A Copy of Your Personal Information

You can access the personal information we hold for you by writing to us at this address:
Subject Access Request
No1 CopperPot Credit Union
Slater House,
Oakfield Road,
Cheadle Royal Business Park,
Cheadle,
Cheshire
SK8 3GX

 

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 or incomplete. Please contact us if you want to do this.

If you do, we will take reasonable steps to check its accuracy and correct it.

 

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 keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that 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 or to exercise legal rights. In this situation, we would not use or share your information in other ways while 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 do not want us to delete it
  • It not relevant anymore, 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 keep on using it.

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

 

How to Make a Complaint

Please let us know if you are unhappy with how we have used your personal information. You can contact us by email www.no1copperpot.com, or by telephone 0161 741 3160, or by letter to Slater House, Oakfield Road, Cheadle Royal Business Park, Cheadle, Cheshire SK8 3GX.

You also have the right to complain to the Information Commissioner’s Office (ICO). You can find out how to complain on their website at https://ico.org.uk/

 

Cookies

To find out more about how we use cookies please see our cookie privacy notice by clicking here Cookies. No1 CopperPot Credit Union is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority under registration number 213301.

 

Appendix 1

RECORD RETENTION PERIOD
Information, data or record Period for retaining record & accompanying notes
Member Data

e.g. data stored within the operating software, electronic storage of documentation, which includes,

member application, Equifax, any ID documentation, loan application, loan agreements, mortgage agreements.

6 years from the date when the membership ceases.

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.

Complaints, records, letters, responses & customer communications received by an FCA regulated firm 3 years
Mortgage documentation where members have not taken up the mortgage e.g. fact find 6 months from date of withdrawal.
Marketing, promotion, press releases 2 years after last action
Accounting records – HMRC records, bank and credit card statements, invoices and reconciliations 6 years + current year
Application forms and interview notes (for unsuccessful candidates) 1 year from date of interview
Records documenting the Credit Union’s relationships and responsibilities to statutory and/or regulatory bodies and its legal responsibilities Permanent
Compliance monitoring records. 3 years after they have ceased selling the product
Rules Permanent
AGM Minutes Permanent
Health & Safety:

Accident books & completed accident record forms.  Accident/incident investigation reports

5 years
Health & Safety:

Employers Liability Insurance Certificate (on display)

Permanent
Health & Safety:

First Aider Training

5 years

No1 CopperPot Credit Union, Privacy Notice, Version 6, updated 26th June 2020