Privacy Notice

Who We Are

No1 CopperPot Credit Union.

We gather and process your personal information in accordance with this privacy notice and in compliance with the relevant Data Protection Regulation and laws. This notice provides you with the necessary information regarding your rights and our obligations, and explains how, why and when we process your personal data.

No1 CopperPot’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. 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 info@no1copperpot.com.

 

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.

 

Information That We Collect

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.

The personal data that we collect from you is: –

  • Name
  • Date of Birth
  • Home Address
  • Work address
  • Personal Email
  • Business Email
  • Home Telephone Number
  • Mobile Telephone Number
  • National Insurance Number
  • Nationality
  • Details of your family members and next of kin

 

Where We Collect Personal Information From

Data you give to us:

  • When you apply for our products and services
  • When you talk to us on the phone or in person
  • When you use our website
  • 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 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 third parties we work with:

  • 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.

 

How We Use Your Personal Data

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 fulfill 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
  • Our legitimate interests
  • Our legal duty
  • Complying with regulations that apply to us
  • Being efficient about how we fulfil our legal duties
  • To exercise our rights set out in agreements or contracts
  • Fulfilling contracts
  • 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 to provide the below services and business functions; 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: www.equifax.co.uk/crain; Callcredit  www.callcredit.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’ll use this data to:

  • Help us to assess whether you are able to afford to make repayments
  • Make sure what you’ve 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 organizations 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

CallCredit – www.callcredit.co.uk/crain

Experian – www.experian.co.uk/crain

 

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; Callcredit www.callcredit.co.uk/crain

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

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.

You also have the right to request erasure of your personal data or to restrict processing in accordance with the data protection laws; as well as 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.

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

Therefore, when we send you an information 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 may use your personal information to tell you about relevant products and offers. 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.  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.

You can ask us to stop sending you marketing messages by contacting us at any time.

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 update your choices at any time by contacting us.

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

 

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 are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.

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 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 your personal information we hold by writing to us at this address:

Subject Access Request
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 don’t want us to delete it.
  • It 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 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 online on www.no1copperpot.com or by telephone on 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 www.no1copperpot.com/privacy-policy/

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.  However, no data will be deleted prior to the PPI claims deadline in August 2019.

 

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 (including HMRC records) 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
Supplier, business relationship documents, contracts, SLA’s, audits, reviews etc End of relationship + 6 years
Compliance monitoring records. 6 years
Memberships, certification and/or accreditation with professional associations e.g. Building Societies Association. End of membership/accreditation + 1 year
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