PRIVACY NOTICE

How Glasgow Credit Union uses your personal information

Looking after your information

The Data Protection Act requires Glasgow Credit Union to manage personal information in accordance with the Data Protection Principles. In particular, we are required to process your personal information fairly and lawfully. This means that you are entitled to know how we intend to use any information you provide. You can then decide whether you want to give it to us in order that we may provide the product or service that you require. All our employees are personally responsible for maintaining member confidentiality. We provide training and education to all employees to remind them about their obligations. In addition, our policies and procedures are regularly audited and reviewed.

Who we are

Your information will be held by Glasgow Credit Union.

Where we obtain your information

Your personal information will be held securely in Glasgow Credit Union systems so that we can manage your relationship with us. This will include information you provide when you apply to us and any additional information provided by you or others in various ways, including:

(a) in applications, emails and letters, during telephone calls and conversations in the credit union offices, when registering for services, in member surveys, when you participate in competitions and promotions and through Glasgow Credit Union’s website.
(b) from analysis (for example, the amount, frequency, location, origin, and recipient) of your payments either to or from you and other transactions, including the creation of profiles used to uniquely identify you when you use our online, mobile and telephony services which are used to help us combat fraud and other illegal activity; and
(c) information Glasgow Credit Union receives from or through other organisations (for example credit reference agencies, social networks, and fraud prevention agencies) whether in the course of providing products and services to you or otherwise, and from information we gather from your use of and interaction with our internet and mobile banking services and the devices you use to access them.

We will not retain your personal information for longer than is necessary for the maintenance of your account, or for legal or regulatory requirements.

Central member database

We hold member information on a central member database which is also the register of our members. Individual account statements and communications will always be sent to the address of the first named account holder associated with the account in question.

We only hold one email address and one of each type of phone number per member and these apply to any accounts held with Glasgow Credit Union. Any changes to these details applied as part of account or policy opening processes will update details we already hold for you. If the details are recorded for a one-off process request, they will not be retained for future use.

If you hold a product with Glasgow Credit Union and you notify us of changes to your personal details, we will update all of your Glasgow Credit Union records unless you ask us not to.

How we share your information within Glasgow Credit Union

We may share the personal information we hold about you within Glasgow Credit Union for the following administrative activities:

a) providing you with products and services and notifying you about either important changes or developments to the features and operation of those products and services;
b) responding to your enquiries and complaints;
c) administering offers, competitions, and promotions;
d) facilitating the secure access to online platforms;
and also for the following data sharing activities:
e) updating, consolidating, and improving the accuracy of our records;
f) undertaking transactional analysis;
g) arrears and debt recovery activities;
h) testing new systems and checking upgrades to existing systems;
i) crime detection, prevention, and prosecution;
j) evaluating the effectiveness of marketing, and for market research and training;
k) member modelling, statistical and trend analysis, with the aim of developing and improving products and services;
l) assessing lending and insurance risks across the Glasgow Credit Union;

By sharing this information it enables us to better understand your needs and run your accounts in the efficient way that you expect.

Your data may also be used for other purposes for which you give your specific permission, or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.

When we may share your information

We will treat your personal information as private and confidential but may share it with each other and disclose it outside the Glasgow Credit Union if:

a) allowed by this agreement;
b) you consent;
c) needed by subcontractors to help us manage your records;
d) HM Revenue & Customs or other authorities require it;
e) the law, regulatory bodies (including for research purposes), or the public interest permits or requires it;
f) required by us or others to investigate or prevent crime;
g) needed by market research companies to assist us in providing better products and services for you;
h) any other parties connected with your account (including guarantors) need it;
i) required as part of our duty to protect your accounts, for example, we are required to disclose your information to the UK Financial Services Compensation Scheme (FSCS)

How we share your information with other organisations

Glasgow Credit Union may disclose your personal information to other people or organisations if any of the following applies:

• we have your consent; or
• for the purposes of them providing products, services or research in association with or on behalf of Glasgow Credit Union; or
• for the purpose of them providing administrative, processing, analytical or
• other similar services to Glasgow Credit Union to assist Glasgow Credit Union in the provision of products and services to our members; or
• for the purpose of verifying the information you have given us, for example, verifying your income when assessing you for credit; or
• for the purposes of improving our products, services and marketing communications, with specialist market research organisations who may contact you on our behalf and invite you to take part in market research, but who will not be allowed to use your information for anything else; or

• where we may transfer rights and obligations under any contract with you; or
• where we are required or permitted to do so by law or regulation.

Glasgow Credit Union does not share or give any information to external companies for their own marketing purposes.

Using your information to prevent terrorism and crime

The Government also requires us to screen applications that are made to us to ensure we are complying with the international fight against terrorism and other criminal activities. As a result of this, we may need to disclose information to government bodies.

Sharing your personal information between 1st and 2nd charge lenders

If you have a secured loan or mortgage with us, we may need to share information with other lenders who also hold a charge on your property.

Joint applicants

If you give personal information about someone else (such as a joint applicant) then you should not do so without their permission. Where information is provided by you about someone else, or someone discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this privacy notice.

Sometimes, when you open a joint account or product, this may mean that your personal data will be shared with the other applicant. For example, transactions made by you will be seen by your joint account holder and vice versa.

How we manage sensitive personal information

The Data Protection Act defines certain information as ‘sensitive’ (racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences). We will only use this information to provide the service you require and we will ask for your explicit consent. As a member, there may be times when you give us sensitive information.

Using companies to process your information outside the EEA

Glasgow Credit Union will not use any companies outside the European Economic Area (EEA) to process your information.

Using credit scoring

When you apply for credit, an automated system known as credit scoring may be used when considering whether to agree to the borrowing. It is a method of assessing your likely conduct of an account based on a range of data, including the conduct of previous similar accounts. It is a system widely used by credit providers to help make fair and informed decisions on lending.

Credit scoring takes account of information from three sources – the information you provide on your application, information provided by credit reference agencies and information that may already be held about you by Glasgow Credit Union. A credit scoring system will consider information from these sources, to make an overall assessment of your application.

The credit scoring methods used are regularly tested to ensure they remain fair, effective and unbiased.

Using a credit scoring system helps us to lend responsibly. If you submit an application and it is declined through this automated process, you can contact us within 21 days to have the decision reconsidered. You also have the right to ask that the decision is not made based solely using a credit scoring system.

How we use credit reference agencies

Credit Reference Agencies (CRAs) collect and maintain information about consumers’ and businesses’ credit behaviour. This includes Electoral Register, fraud prevention, and credit information – including details of previous applications and the conduct of your accounts – and public information such as County Court Judgements, decrees, and bankruptcies.

The information that Glasgow Credit Union and other organisations provide to credit reference agencies about you, or your financial associates, may be provided to other organisations and used by them and us to:

a) help make decisions, for example, when:
(i) checking details on applications for credit and credit-related or other facilities;
(ii) managing credit and credit-related accounts or facilities;
(iii) recovering debt;
(iv) checking details of job applicants and employees;
b) detect and prevent crime, fraud and money laundering;
c) check your credit history;
d) verify your identity if you, or someone financially linked to you, apply for services;
e) trace your whereabouts; and
f) undertake research, statistical analysis and systems testing.

If a Glasgow Credit Union needs to make a credit decision when you apply for a credit-based product or service (e.g. mortgage, personal loan), your records will be searched, along with those of anyone who is financially associated with you such as your spouse or partner. The CRA will keep a record of this search and place a “footprint” on your credit file, whether or not the application proceeds.

Debt Recovery process

We may give details of your account and how you conduct it to credit reference agencies, including if you borrow and do not repay in full and on time. If you fall behind with your payments and a full payment or satisfactory proposals are not received within 28 days of a formal demand being issued, then a default notice may be recorded with the CRAs. Any records shared with CRAs will remain on file for 6 years after your account is closed, whether it has been settled by you or as a result of a default. Other organisations may see these searches and updates if you apply for credit in the future, and these may affect your ability to borrow from other lenders.

In addition, we may authorise a third party such as a debt collection agent or a solicitor to act on our behalf in the recovery of the debt. If we decide to take this action we will inform you before we disclose your details to them.
If we are unable to locate you to discuss the situation, we may pass your details to a tracing agency.

Joint Accounts and credit reference agencies

If you apply for or hold an account in joint names, or tell us that you have a spouse/ partner or financial associate, a financial association will be created between your records, including any previous and subsequent names used by you. This means that your financial affairs may be treated as affecting each other. These links will remain on your and their files until such time as you or your partner is successful in applying for a disassociation with the CRAs to break that link. You must be sure that you have their agreement to disclose information about them. Searches may be made on all joint applicants, and search footprints will be left on all applicant records.

You have a right to apply to the credit reference agencies for a copy of your file.
We carry out most of our credit searches using Experian, but details of how you have run your account(s) may be disclosed to all the credit reference agencies. The information they hold may not be the same and there is a small fee that you may need to pay to each agency that you apply to. Their addresses are:

Call Credit
Online: www.callcredit.co.uk/consumer-solutions
By phone: 0870 060 1414
By post: Consumer Services, Callcredit Limited, PO Box 491, LEEDS LS3 1WZ

Equifax
Online: www.equifax.co.uk
By phone: 0844 335 0550
By post: Equifax Credit File Advice Centre, PO Box 1140, Bradford, BD1 5US

Experian
Online: www.experian.co.uk
By phone: 0844 481 8000
By post: Experian Ltd, PO Box 8000, Nottingham, NG80 7WF

Using fraud prevention agencies

We have systems that protect our members and ourselves against fraud and other crime. Member information can be used to prevent crime and trace those responsible. We will share your personal information from your application with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

• Checking details on applications for credit and credit related or other facilities
• Managing credit and credit related accounts or facilities
• Recovering debt
• Checking details of job applicants and employees

If you wish to receive details of the relevant fraud prevention agencies, please contact Member Services by calling 0141 274 9933 or by email [email protected]

How we check your identity

We may ask you to provide physical forms of identity verification when you open your account and/or we provide services to you. Alternatively, we may search Credit Reference Agency files in assessing your application and/or in the provision of services to you. The agency also gives us other details and information from the Electoral Register to verify your identity. The agency keeps a record of our search, whether or not your application proceeds. Our search is not seen or used by lenders to assess your ability to obtain credit.

Undertaking anti-money laundering checks

To comply with money laundering regulations, there are times when we need to confirm (or reconfirm) the name and address of our members.

Obtaining information about you, and other personal details

When you apply for a mortgage or further borrowing it may be necessary to obtain references, details of your existing financial commitments, and any other information that is required to assess or review lending risks, to recover debts, and to prevent or detect fraud.
Where applicable, your current and previous employers, accountant, landlord, lender, bank, insurance or pension company may be contacted to obtain this information. In limited circumstances, these references may need to be obtained after you open your account.

This may be for regulatory purposes, or if the lending decision needs to be reviewed. Your permission to obtain these references will therefore continue to apply after your account has been opened. It may also be necessary to obtain information or documentation from your solicitor relating to any work they carry out either on your or our behalf.

Using your details for service contact

Making sure we deliver excellent customer service is very important to us and to do this, various methods of communication may be used when sending you information about your account. Most of the time you will be contacted by letter or telephone, but you may also be sent updates by text message or email when it is believed to be appropriate. You can ask us to stop sending these messages at any time.

In addition, you may wish to choose a channel of communication that suits you when you need to contact us. If you need to email a Glasgow Credit Union, we recommend you log into your account online and use the secure email facility under the members’ section of the website. If you send us emails in other ways, such as from your personal account, then remember that the message may not be secure and there is a risk that it could be intercepted. If you choose to send an unsecure email, please keep the amount of confidential information you include to a minimum.

Recording phone calls

We may monitor or record phone calls with you in case we need 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 also be monitored for staff training purposes. We also operate CCTV in our offices.

Using information on social networking sites

As part of our ongoing commitment to understanding our members better, we may research comments and opinions made public on social networking sites such as Twitter and Facebook.

Obtaining a copy of your information

Under the Data Protection Act, you have the right of access to your personal data. The Act allows us to charge a fee of £10 for this service. If anything is inaccurate or incorrect, please let us know and we will correct it. For further details on how to request a copy of your information, please contact the credit union.

Using your personal information to contact you about products and services

Personal contact is an important part of the service and member services may contact you personally by mail, telephone, email or text message to inform you about products and services offered by Glasgow Credit Union that he or she thinks are relevant to you, based on their understanding of your financial needs.

We will only contact you if we think a product or service could be appropriate and relevant to you. This contact may continue after your relationship with us ends. You may opt out of receiving this information at any time by calling us, writing to us or contacting the credit union.
Unless a requirement arises under the particular product or service you receive, we are under no obligation to inform or update you in relation to all or any of the products or services which may be appropriate and relevant to you available from or through us.

For all other members

Glasgow Credit Union will use your personal information so we can provide you with product details and offers that are more relevant to you. This may include products and services from companies outside of our Group if we believe they may be of interest to you or benefit you financially. This contact may continue after your relationship with us ends.

We might contact you by mail, telephone, email, or text message unless you have asked us not to. We may also display personalised messages when you use our secure website or mobile app. You can change your preferences at any time by calling us, writing to us, contacting the credit union or by updating them online.

Unless a requirement arises under the particular product or service you receive, we are under no obligation to inform or update you in relation to all or any of the products or services which may be appropriate and relevant to you available from or through us.

Collection and use of information on our website

The credit union will not collect any personal information about you on this website without your consent. We will let you know what we intend doing with your information before collecting it so that you can decide whether or not to furnish that information to us.

Any information which is provided by you will be treated with the highest standards of security and confidentiality and in accordance with the terms of the Data Protection Act 1998, Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the Protection of Individuals with regard to the Processing of Personal Data and on the Free Movement of Such  Data, and any implementing and/or amending legislation as may be adopted in the United Kingdom from time to time.

If at any time after giving us personal information you decide that you no longer wish us to hold or use this information, or in the case that the information becomes out of date, you are free to notify us, and we will remove or rectify the information within a reasonable time and in accordance with legislative requirements.

You acknowledge and agree that in certain circumstances we may be obliged to disclose personal information relating to you to third parties, for example, in order to conform to any requirements of law or to comply with any legal process, as well as to protect and defend the rights of property of The credit union, our licensors and/or our other customers.

Telephone calls may be monitored or recorded to ensure that we carry out your instructions correctly and to help improve the quality of our service and in the interests of security.

Cookies

With regards to the new requirements on Cookies following the revision of the e-Privacy Directive, the credit union is working towards implementing the new requirements in line with guidance from the Information Commissioner’s Office.

To make using our Site as straightforward as possible and to improve the service we offer you, we use cookies.

What are cookies?

Cookies are text files that web servers can store on your computer’s hard drive when you visit a website. There are two main types:

• Transient (or per-session) cookies
  These only exist for your site visit and are deleted on exit. They recognise you as you move between pages, for example, recording items added to an online shopping basket. These cookies also help maintain security.
• Persistent (or permanent) cookies
  These stay on your machine until expiry or deletion. Many are built with automatic deletion dates to help ensure your hard drive doesn’t get overloaded. These cookies often store and re-enter your log-in information, so you don’t need to remember membership details.
  Additionally, cookies can be first or third party cookies. First party cookies are owned & created by the website you’re viewing- in this case by the Credit Union. Third party cookies are owned & created by an independent company, usually a company providing a service to the website owners. In our case, third-party cookies provided from this Site are still subject to the provisions set out below.

What we use cookies for

Internet cookies help you do things online, like remembering log-in details so you don’t have to re-enter them when revisiting a site.

We use cookies to:

• Gather customer journey information across our sites
• Ensure your privacy in our secure sites
• Temporarily store details input into our calculators, tools, illustrations and demonstrations

We use both our own (first party) and partner companies’ (third party) cookies to support these activities.

We don’t use cookies to track people’s Internet usage after leaving our sites.

Services requiring enabled cookies

Some of our services require cookies in your browser to view and use them and to protect your financial and personal information.

Changing your cookie settings

You are not obliged to accept cookies that we send to you and you can,, in fact modify your browser so that it will not accept cookies. To enable or disable cookies, follow the instructions provided by your browser (usually located within the Help, Tools or Edit facility). Alternatively, an external resource is available, providing specific information about cookies and how to manage them to suit your preferences.

Please note that should you choose to set your browser to disable cookies, you may not be able to access secure areas of this Site, for example, any online accounts you may hold.

Disclaimer

The credit union, its directors, employees, servants and agents, affiliates or other representatives and their respective parent and subsidiary companies, shall not be liable in respect of any claims, emergencies, demands, causes of action, damages, losses, expenses, including without limitation, reasonable legal fees and costs of proceedings arising out of or in connection with the use and/or dissemination of personal information relating to you in accordance with this privacy policy and your consents.

You should be aware that where you link to another website from the credit union website, that the credit union has no control over that other website. The credit union has no responsibility for the privacy practices of other websites.

Amendments

The credit union reserves the right at its sole discretion to amend this privacy statement at any time, and you should regularly check this privacy statement for any amendments.

Viewing notifications

Organisations must lodge a notification with their Regulator describing the purposes for which they process personal information. The details are publicly available from the Regulator’s office and you can view ours at: https://ico.org.uk/about-the-ico/what-we-do/register-of-data-controllers/

Changes to Privacy Notice

We keep our privacy notice under regular review and we will reflect any updates within this notice. This privacy notice was last updated on 23rd March 2017.

Further information

For further information please contact the credit union on 0141 274 9933 or email [email protected]