PRIVACY NOTICE

How Glasgow Credit Union uses your personal information

1.  Who we are

Glasgow Credit Union is a “data controller” in respect of personal information we process in connection with our business (including the products and services that we provide). In this notice, references to “we”, “us” or “our” are references to Glasgow Credit Union. We are registered as a data controller with the Information Commissioner’s Office (ICO), the supervisory authority for data protection within the United Kingdom. Our registration number is Z6604434.

This privacy notice (the “Privacy Notice”) will apply to all personal information processing activities carried out by Glasgow Credit Union.

If you have any data protection issues or queries, please direct these to:

Data Protection Officer, Glasgow Credit Union, 95 Morrison Street, Glasgow, G5 8BE.  Telephone 0141 274 5405 or email: compliance@glasgowcu.com

We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with our business. “Personal information” means information about a living individual who can be identified from that information (either by itself or when it is combined with other information). We may update this Privacy Notice from time to time. When we do, we will publish the updated Privacy Notice on our website. If we make any significant changes, we will bring this to your attention via a bold notification on our website and/or by sending a copy to you to either an e-mail or home address registered with us.

2.  The information we process

We collect and process various categories of personal information at the start of, during our and, even after, your relationship with us. We will limit the collection and processing of information to only what is necessary to achieve one or more purposes as identified in this notice. Personal information may include:

1. basic personal information, including name and address, date of birth and contact details;
2. financial information, including account and transactional information and history;
3. information about your family, lifestyle and social circumstances (such as dependents, marital status, next of kin and contact details);
4. information about your financial circumstances, including proof of income and expenditure, credit and borrowing history and needs and goals;
5. education and employment information;
6. goods and services provided;
7. visual images (such as copies of passports or CCTV images);
8. audio recordings of meetings of members for the explicit purpose of ensuring accuracy; and
9. online profile and social media information and activity, based on your interaction with us and our websites and applications, including for example, your credit union profile and login information, Internet Protocol (IP) address, website visits etc.

We may also process some special category personal data for specific and limited purposes, such as detecting and preventing financial crime or to make our services accessible to customers.

We will only process special categories of information where we’ve obtained your explicit consent or are otherwise lawfully permitted to do so (and then only for the particular purposes and activities set out at Schedule A for which the information is provided). This may include:

• physical or psychological health details or medical conditions;

Where permitted by law, we may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime or to comply with laws relating to money laundering, fraud, terrorist financing, bribery, corruption and international sanctions. It may involve investigating and gathering intelligence on suspected financial crimes, fraud, threats and sharing data between banks or with law enforcement and regulatory bodies.

3.  How we obtain information

Your information is made up of all the financial and personal information we collect and hold about you and your transactions. It includes:

1. information you give to us;
2. information that we receive from third parties who provide services to you or us, such as credit reference, agencies, Open Banking providers, insurers, police, fraud prevention or government agencies,
3. information that we learn about you through our relationship with you and the way you operate your accounts and/or services, such as the payments made to and from your accounts;
4. information that we gather from the technology which you use to access our services such as:
   • an IP address;
   • telephone number;
   • cookies;
   • website log in information

4.  Your information

We want to make sure you are aware of your rights in relation to the personal information we process about you. We have described those rights and the circumstances in which they apply in the table below.

If you wish to exercise any of these rights, if you have any queries about how we use your personal information that are not answered here, or if you wish to complain please refer to the contact details set out in Section 1 above.

Rights	Description
Access – You have a right to get access to the personal information we hold about you.	If you would like a copy of the personal information we hold about you, please refer to the contact details set out in Section 1 above.
Rectification – You have a right to rectification of inaccurate personal information and to update incomplete personal information.	If you believe that any of the information that we hold about you is inaccurate, you have a right to request that we rectify the inaccurate personal information.
Erasure – you have a right to request that we delete your personal information, in certain circumstances	You may request that we delete your personal information if you believe that: we no longer need to process your information for the purposes for which it was provided; we have requested your permission to process your personal information and you wish to withdraw your consent; we are not using your information in a lawful manner or; where we are required to erase your personal information to comply with local law. Note: We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Restriction – You have a right to request us to restrict the processing of your personal information, in certain situations	You may request us to restrict processing your personal information if you believe that: any of the information that we hold about you is inaccurate; we no longer need to process your information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or we are not using your information in a lawful manner; You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Portability – You have a right to data portability, in certain circumstances	Where we have requested your permission to process your personal information or you have provided us with information for the purposes of entering into a contract with us, you have a right to receive the personal information you provided to us in a portable format. You may also request us to provide it directly to a third party, if technically feasible. We’re not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you. If you would like to request the personal information you provided to us in a portable format, please refer to the contact details set out in Section 1 above. Note that this right only applies to your personal information which you initially provided to us, which is processed based on your consent or based on the performance of a contract between us and which is processed by us using automated means.
Objection – You have a right to object to the processing of your personal information.	You have a right to object to us processing your personal information (and to request us to restrict processing) for the purposes described in Section C of Schedule A – Purposes of Processing (below) unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests or where we need to process your information to investigate and protect us or others from legal claims. Depending on the circumstances, we may need to restrict or cease processing your personal information altogether, or, where requested, delete your information.
Marketing – You have a right to object to direct marketing.	You have a right to object at any time to processing of your personal information for direct marketing purposes, including profiling you for the purposes of direct marketing. For more information see Section 8.
Withdraw consent – You have a right to withdraw your consent.	Where we rely on your consent to process your personal information, you have a right to withdraw your consent at any time. We will always make it clear where we need your consent to undertake specific processing activities.
Lodge complaints – You have a right to lodge a complaint with the Supervisory Authority in the UK, The Information Commissioner’s Office (ICO)	If you wish to raise a complaint on how we have handled your personal information, you can contact our Data Protection Officer who will investigate the matter. We hope that we can address any concerns you may have, but you can always contact the ICO if you’re unhappy or dissatisfied. Visit ico.org.uk

5.  Failure to provide personal information

Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that data, we may not be able to perform, or even enter, the contract (for example, to provide you with financing or other services). In this case, we may have to cancel such financing or services you have with us, but we will notify you if this is the case at the time.

6.  Sharing with third parties

We will not share your information with anyone outside Glasgow Credit Union except:

1. where we have your permission;
2. where required for your product or service;
3. where you have subscribed to the “Big G Lottery”;
4. where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world;
5. with other banks and third parties where required by law to help recover funds that have entered your account as a result of a misdirected payment by such a third party;
6. with third parties providing services to us, such as market analysis and benchmarking, correspondent banking, and agents and sub-contractors acting on our behalf, such as the companies which print our account statements;
7. with other banks to help trace funds where you are a victim of suspected financial crime and you have agreed for us to do so, or where we suspect funds have entered your account as a result of a financial crime;
8. with debt collection agencies;
9. with credit reference and fraud prevention agencies;
10. with Open Banking providers that we use for account information service, for the purpose of inviting you to use this service and share third party account information with us. (This is currently Experian and further information can be found at here;
11. with third-party guarantors or other companies that provide you with benefits or services (such as insurance cover) associated with your product or service;
12. where required for a proposed sale, reorganisation, transfer, financial arrangement, asset disposal or other transaction relating to our business and/or assets held by our business;
13. in anonymised form as part of statistics or other aggregated data shared with third parties; or
14. where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above.

If you ask us to, we will share information with any third party that provides you with account information or payment services.

If you ask a third-party provider to provide you with account information or payment services, you are allowing that third party to access information relating to your account. We will not be responsible for any third party use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you.

In the event that any additional authorised users are added to your account, we may share information about the use of the account by any authorised user with all other authorised users.

Glasgow Credit Union will not share your information with third parties for their own marketing purposes without your permission.

7.  Transferring information overseas

We may transfer your information to organisations in other countries on the basis that anyone to whom we pass it protects it in the same way as we do, or, in accordance with applicable laws.

In the event that we transfer information to countries outside of the European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway), we will only do so where:

1. we have your explicit consent;
2. the European Commission has decided that the country or the organisation we are sharing your information with will protect your information adequately;
3. the transfer has been authorised by the relevant data protection authority; and/or
4. we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the European Commission) to ensure your information is adequately protected. If you wish to obtain a copy of the relevant data protection clauses, please refer to the contact details set out in Section 1 above.

8.  Marketing information

Where you have provided consent for us to do so, we will process your personal information in order to send you information about products and services which may be of interest to you by phone, email, text and other forms of electronic communication.

We may also send you information as above where we have a legitimate interest in doing so and where you have not objected to us doing so. In this situation, any information will be in respect of your similar products and services only.

If you change your mind about how you would like us to contact you or you no longer wish to receive this information, you can tell us at any time by contacting us on 0141 274 5423 or by email to marketing@glasgowcu.com

9.  Communications about your account

We will contact you with information relevant to the operation and maintenance of your account (including updated information about how we process your personal information), by a variety of means including via our website, mobile app, email, text message, post and/or telephone. If at any point in the future you change your contact details, you should tell us promptly about those changes, in order that we can ensure your account details remain accurate.

We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes outlined in Schedule A – Purposes of Processing.

10.  Credit reference and fraud prevention agencies

We may access and use information from credit reference and fraud prevention agencies when you open your account and periodically to:

1. manage and take decisions about your accounts, including assessing your creditworthiness and checks to avoid customers becoming over-indebted;
2. prevent criminal activity, fraud and money laundering;
3. check your identity and verify the accuracy of the information you provide to us; and
4. trace debtors and recover debts.

 Application decisions may be taken based solely on automated checks of information from credit reference and fraud prevention agencies and internal credit union records. To help us make decisions whether or not to give you credit, we use a system called credit scoring to assess your application. To work out your credit score, we look at the information you give us when you apply; information from credit reference agencies that will show us whether you’ve kept up to date with payments on any credit accounts (that could be any mortgages, loans, credit cards or overdrafts), or if you’ve had any court action such as judgments or bankruptcy; your history with us such as maximum level of borrowing; and affordability, by looking at your available net income, existing debts, and if you have shared your bank account transactions via Open Banking. You have rights in relation to automated decision-making, including a right to appeal if your application is refused.

We will continue to share information with credit reference agencies about how you manage your account including your account balance, payments into your account, the regularity of payments being made, credit limits and any arrears or default in making payments, while you have a relationship with us. This information will be made available to other organisations (including fraud prevention agencies and other financial institutions) so that they can take decisions about you, your associates and members of your household.

If false or inaccurate information is provided and/or fraud is identified or suspected, details will be passed to fraud prevention agencies. Law enforcement agencies and other organisations may access and use this information.

If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or we may stop providing existing services to you.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services, financing or employment to you. Fraud prevention agencies can hold your information for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

When credit reference and fraud prevention agencies process your information, they do so on the basis that they have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect their business and to comply with laws that apply to them.

If you would like a copy of your information held by the credit reference and fraud prevention agencies we use, or if you want further details of how your information will be used by credit reference agencies, please visit their websites or contact them using the details below.

The three main credit reference agencies TransUnion, Equifax, Experian, and Crediva. Each use and share personal information they receive about you that is part of, derived from or used in credit activity and this is explained in more detail in the Credit Reference Agency Information Notice available at any of the following:

Credit reference agency	Contact details
TransUnion Limited (transunion.co.uk/crain)	Post: TransUnion Information Group, One Park Lane, Leeds, West Yorkshire LS3 1EP. Website: www.transunion.co.uk/crain Email: consumer@transunion.co.uk Phone: 0330 024 7574
Equifax Limited	Post:  Equifax Ltd, Customer Service Centre, PO Box 10036, Leicester, LE3 4FS Website:  www.equifax.co.uk/crain Phone:  0333 321 04043 or 0800 014 2955
Experian Limited	Post:  Experian, PO Box 9000, Nottingham, NG80 7WF Website: www.experian.co.uk/crain Email:  consumer.helpservice@uk.experian.com Phone:  0344 481 0800 or 0800 013 8888
Crediva	Post: Crediva Limited, LexisNexis Risk Solutions, Global Reach, Dunleavy Drive, Cardiff, CF11 0SN Website: Crediva Limited Email: enquiry@crediva.co.uk Phone: 0808 129 3210

Cifas is the UK’s leading fraud prevention service. Their members are organisations from all sectors, sharing their data across those sectors to reduce instances of fraud and financial crime.

Before providing you with a service we may check details against the Cifas database. For further information on Cifas and how we process your information please see:

Cifas

Post:      Consumer Affairs, Cifas, 6th Floor, Lynton House 7-12 Tavistock Square, London, WC1H 9LT Website:      https://www.cifas.org.uk/fpn Phone:      0330 100 0180

11.  How long we keep your information

By providing you with products or services, we create records that contain your information, such as customer account records, activity records, tax records and lending and credit account records. Records can be held on a variety of media and formats (physical/paper or electronic). We manage records to help us serve our customers (for example for operational reasons, such as dealing with any queries relating to your account) and to comply with legal and regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities.

Retention periods for records are determined based on the type of record, the nature of the activity, product or service. We normally keep customer account records for up to six years after your relationship with the credit union ends, whilst other records are retained for shorter periods, for example, 30 days for CCTV records or 6 months for call recordings. Retention periods may be changed from time to time based on business or legal and regulatory requirements.

We may, on exception, retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that the credit union will be able to produce records as evidence if they’re needed.

If you would like more information about how long we keep your information, please refer to the contact details set out in Section 1 above.

12.  Security

We are committed to ensuring that your information is secure whilst held and processed by us and with any third parties who act on our behalf. Where we do engage a third party to act on our behalf, we ensure they undertake processing activities using the same standards as ourselves and with suitable data processing or sharing agreements in place.

13.  Complaints

We seek to directly resolve any complaints about how we handle personal information and would request you contact us in the first instance. If you are not happy thereafter, you also have the right to complain to the Information Commissioner’s Office (ICO) in relation to our use of your information. The Information Commissioner’s contact details are noted below:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Or see: https://ico.org.uk/make-a-complaint/

We keep this privacy notice under regular review and if there are any significant updates, we will draw attention to these via a banner page on our website.

Download a PDF version of this privacy notice