Introduction

Cavan Credit Union is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information and to provide you with information regarding the processing of information about you for account/loan related purposes and other general purposes.

Our contact details are:

Cavan Credit Union, 83 Main Street, Cavan, H12 FX22

Phone:   049 4331715

Email: info@cavancu.ie

Our Data Protection Officer contact details are:

Name:  John Nealon

Phone: 042 9749515

Email: info@dataprotectionservice.ie

Purpose of Data Collection, Processing or Use

A credit union is a member-owned financial cooperative, democratically controlled by its members, and operated for the purpose of promoting thrift, providing credit at competitive rates, and providing other financial services to its members. Data collection, processing and use are conducted solely for the purpose of carrying out the abovementioned objectives.

What personal data do we use?

We may collect, store, and use the following categories of personal information about you, depending on the services that you require, including:

• Your name, address, date of birth, email, telephone, financial data, status and history, transaction data; contract data, details of the credit union products you hold with us, signatures, identification documents, salary, occupation, accommodation status, mortgage details, previous addresses, spouse, partners, nominations, Tax Identification/PPSN numbers, passport details, interactions with credit union staff and officers on the premises, by phone, or email, current or past complaints, CCTV footage, telephone voice recordings, relationship to member, bank details (to allow payment/transfer of nominated property)

Depending on the services that you require, we need different categories of information in the list above to allow us to identify you, contact you, comply with our legal obligations, meet legal and compliance obligations and requirements under the Rules of the Credit Union and in order that we perform our contract with you.  We also need your personal identification data to enable us to comply with legal obligations. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal data

How we use particularly sensitive personal data 

We may also collect, store and use “special categories” of more sensitive personal information including Information about your health, including any medical condition, health and sickness (for Insurance and associated purposes).

”Special categories” of particularly sensitive personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We may process special categories of personal data in the following circumstances:

1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations and in line with our data protection policy.
3. Where it is needed in the public interest, and in line with our data protection policy.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. The following section details specific Data Protection related issues to differing services.

SPECIFIC PRIVACY NOTICES

Account Opening Privacy Notice

Why we process your personal data

• To open and maintain an account for you;
• To meet our obligations to you under the Credit Union’s Standard Rules
• To contact you in respect of your account and any product or service you avail of; and
• To comply with our legal obligations, e.g. Anti-money laundering; to identify connected borrowers; etc

Lending Privacy Notice

The purposes for which we use your personal data:

The credit union will use your personal data to assist it in carrying out the following:

• Assessing your loan application and determining your creditworthiness for a loan.
• Verifying the information provided by you in the application.
• We are obliged to purchase loan protection and life savings protection from ECCU
• Conducting credit searches and making submissions to the Central Credit Register.
• Administering the loan, including where necessary, to take steps to recover the loan or enforce any security taken as part of the loan.
• We may use credit scoring techniques and other automated decision-making systems to either partially or fully assess your application.
• To comply with Central Bank Regulations to determine whether you are a connected borrower or related party borrower.
• Providing updates on our loan products and services by way of directly marketing to you – subject to appropriate consent.

Guarantor Privacy Notice

Why we process your personal data

• To ensure repayment of the loan and to facilitate the requirements of the contract between you and the credit union
• Assessing the loan application and determining your creditworthiness to guarantee the loan.
• Verifying the information provided by you in the application.
• To contact you in respect of your guarantee in the event of the change of circumstance of the member/ member getting into arrears
• Collection of the debt
• Conduct due diligence/credit checking
• To comply with Central Bank Regulations to determine whether you are a connected borrower or related party borrower.

Nominations Privacy Notice

How we collect the information

We collect personal information about nominees from Nomination form completed by the member.

Nominations

• The ability of a member over the age of 16 to nominate individuals to receive property in their credit union account on their death is a unique facility available for credit union members under the credit union legislation by which we operate. The nominated property does not form part of a deceased person’s estate.
• The member may nominate a person(s) of choice to receive their property (i.e. shares) in the credit union presently up to a maximum value of €23,000. Any amount in excess of this balance forms part of the member’s estate and must be dealt with in accordance with the law.
• The information relating to you as nominee has been provided to us by the member during their lifetime.
• A member may change the details of their nomination as often as they like during the course of their membership with the credit union. In addition, there may be instances where a nomination is revoked through marriage or civil partnership, or the death of the nominee before the nominating member. There is therefore no guarantee that a nomination will be valid until the member has passed away and the validity of the nomination is confirmed by the credit union. As such, we are unable to contact individuals directly to advise them that we are processing their information.
• Where a member makes a nomination, we are required under the credit union legislation by which we operate to keep a record of all persons nominated (along with any revocation or variation of any nomination).
• As this is the first time we have communicated with you in relation to the nomination, we are required under data protection legislation to provide you with the information contained within this privacy notice.

We need the categories of information in the list above to allow us to record your details in our register of nominations, identify you, to contact you and then upon order upon the passing of the member, to process the nomination (subject to a valid nomination) and transfer any nominated property to you, the nominee(s).

Connected Party Privacy Notice

Why we process your personal data

• Assessing the loan application and determining your creditworthiness as a connected party/related party.
• Verifying the information provided by you in the application.
• Conduct due diligence/credit checking
• To comply with Central Bank Regulations to determine whether you are a connected borrower or related party borrower.

Your Marketing Preferences

As part of improving our service to you, from time to time, we would like to inform you of goods, services, competitions and/or promotional offers available from us.   We may wish to use different means when sending such marketing communications.

You have a right to notify us free of charge at any time that you wish to refuse such marketing by writing to us at our address at the top of this document or by using the “opt-out” options in any marketing message we send you. Please contact us directly should you wish to change or withdraw your consent.

Other Information

How do we keep your information safe?

The safety of your information is very important to us and Cavan Credit Union has implemented technical and organisational Measures (TOMs) for the security of your information. Our staff are trained in data protection and IT security awareness. We keep our computers, files and building secure. Transit of paper files is strictly limited.  We operate a Clean Desk policy and no member information is left in the open or on view to external parties. Electronic copy files are stored on our proprietary IT system which requires user authentication to access it.  Back-ups of electronic files are stored securely off site. Back-ups are tested on a regular basis.  Laptops are encrypted at hard-drive level.  Use of memory sticks and other portable drives is restricted to management personnel, and all external drives are encrypted. All files and hard drives being disposed of are shredded and this is certified by the shredding service provider.

When you contact us by phone to ask about your information, we will ask you to verify your identity.

How secure is my information with third-party service providers?

All our third-party service providers are required to take appropriate security measures to protect your personal data in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes unless they are deemed to be controllers in their own right. We only permit them to process your personal data for specified purposes and in accordance with our instructions. Usually, information will be anonymised but this may not always be possible. The recipient of the information will also be bound by confidentiality obligations.

Reporting of Data Breaches

Our Data Protection Officer advises on how we can best understand risks to your data rights and freedoms, processes implemented to protect these and has responsibility to report to the Office of the Data Protection Commissioner if there is any breach of your data or our obligations.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or we may be prevented from complying with our legal obligations.

Change of purpose

You can be assured that we will only use your data for the purpose it was provided and in ways compatible with that stated purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Profiling

We sometimes use systems to make decisions based on personal data we have (or are allowed to collect from others) about you. This information is used for loan-assessment, provisioning and anti-money laundering purposes and compliance with our legal duties in those regards. We may also carry out profiling in order to tailor our marketing to you.

Data Retention Periods

We will retain permanently, the name in our register of nominations. Member nomination forms (and any other documentation related to the nomination will be retained for a period of six years after the relationship with the member has ended (e.g. the member passing away).

We will only retain your personal data for as long as necessary to fulfil the purpose(s) for which it was obtained, taking into account any legal/contractual obligation to keep it. Where possible we record how long we will keep your data. Where that is not possible, we will explain the criteria for the retention period. This information is documented in our Retention Policy. Once the retention period has expired, the respective data will be permanently deleted. Please see our retention periods below.

• Accounting records required to be kept further to the Credit Union Act, 1997 (as amended) must be retained for not less than six years from the date to which it relates.
• The money laundering provisions of Anti-Money Laundering legislation require that certain documents must be retained for a period of five years after the relationship with the member has ended.
• We keep income tax records for a period of six years after completion of the transactions to which they relate.
• Loan application information is retained for a period of seven years from the date of discharge, final repayment, transfer of the loan.
• CCTV footage which is used in the normal course of business (i.e. for security purposes, detection of fraud or theft and discovery of errors and omissions) for one month.
• Credit agreements are contracts and as such the credit union retains them for seven years from date of expiration or breach, and twelve years where the document is under seal.
• Loan applications form part of your credit agreement and as such we retain them for seven years.
• Guarantor details will be held for seven years following default of the borrower, date of demand, discharge, transfer or repayment of the loan.

Planned data transmission to third countries

Data may be transferred from us to the UK which is a third country. The data is transferred on the basis of an adequacy regulation by the EU in respect of the UK.

Updates to this notice

We will make changes to this notice from time to time, particularly when we change how we use your information, and change our technology and products. You can always find an up-to-date version of this notice on our website at www.cavancu.ie or you can ask us for a copy.

Our use and sharing of your information

How we may share the information

We may also need to share some of the above categories of personal data with other parties, such as the Irish League of Credit Unions (ILCU) and our advisers such as solicitors, debt collectors or auditors. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations. We may also be required to share some personal data with our regulator the Central Bank of Ireland as required to comply with the law. The Privacy Notice of the ILCU is available at www.creditunion.ie.

Our use of your information

Our legal basis for processing personal data supplied by you for the purpose of this guarantee is in furtherance of this contract and legitimate interest if a credit search /due diligence is conducted.

We will collect and use relevant information about you, your transactions, your use of our products and services, and your relationships with us. We will typically collect and use this information for the following purposes:

Please note that the above rights are not always absolute and there may be some limitations

If you want access and/ or copies of any of your personal data or if you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we send you or a third party a copy your relevant personal data in a reusable format please contact our Data Protection Officer in writing using their contact details above.

There is no fee in using any of your above rights, unless your request for access is clearly unfounded or excessive. We also reserve the right to refuse to comply with the request in such circumstances.

We may need to verify your identity if we have reasonable doubts as to who you are. This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

Ensuring our information is up to date and accurate. We want the service provided by us to meet your expectations at all times. Please help us by telling us straight away if there are any changes to your personal information. If you wish to avail of either of these rights, please contact us using our contact details at the top of this document.

If you wish to discuss any of your personal data or want a specific piece of Data please contact us in the first instance and we will be more than happy to assist you.