Privacy Notice of Wicklow and District Credit Union Limited
Our Contact Details Are:
Address: 3 Main Street, Wicklow, Co Wicklow
Data Protection Officer Contact Details:
Address: 3 Main Street, Wicklow, Co Wicklow
Wicklow and District 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 about you during and after your relationship with us.
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 aforementioned objectives.
What personal data do we use?
We may collect, store and use the following categories of personal information about you:
- Your name, address, date of birth, email, telephone, financial data, status and history, transaction data; contact 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/PPS numbers, passport details, interaction with credit union staff and officers on the premises, by phone or email, current or past complaints, CCTV footage, telephone voice recordings.
We may also collect, store and use the following ‘special categories’ of more sensitive information:
- Information about your health, including any medical condition, health and sickness.
We need all the categories of information in the list above to allow us to identify you and contact you and in order that we can perform our contact 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 information.
If you fail to provide this information
If you fail to provide certain information where 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
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.
How we use particularly sensitive personal information
‘Special Categories’ of particularly sensitive personal information 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 information in the following circumstances:
- In limited circumstances with your explicit consent
- Where we need to carry out our legal obligations and in line with our data protection policy
- Where it is needed in the public interest, and in line with our data protection policy
We sometimes use systems to make decision based on personal information we have (or are allowed to collect from others) about you. This information is used for anti-money laundering purposes and compliance with our legal duties in that regards.
We will only retain your personal information 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. We document the reasons for our retention periods and where possible the retention periods themselves 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 then 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.
- Credit agreements and loan application forms are retained for contracts and should be retained for minimum six years from date of expiration or breach, and twelve years where the document is under seal
- CCTV footage which is used in the normal course of business (i.e. for security purposes) for one month
Planned data transmission to third countries
There are no plans for data transmission to third countries.
Our use and sharing of your information
We will collect and use relevant information about you, your transactions, your use of our products and services and your relationships with us:
- Fulfilling Contract: This basis is appropriate where the processing is necessary for us to manage your accounts and credit union services to you.
- Administrative Purposes: We will use the information provided by you, either contained in this form or any other form or application, for the purpose of assessing applications, processing your applications you make and to maintain and administer any accounts you have with the credit union.
Third parties: we may appoint external third parties to undertake operational functions on our behalf. We will ensure that any information passed to third parties conducting operational functions on our behalf will do so with respect for the security of your data and will be protected in line with data protection law.
- ILCU Affiliation: The ILCU (a trade and representative body for credit unions in Ireland and Northern Ireland) provides professional and business support services such as marketing and public affairs representation, monitoring, financial, compliance, risk, learning and development, and insurance services to affiliated credit unions. As this credit union is affiliated to the ILCU, the credit union must also operate in line with the ILCU Standard Rules (which members of the credit union are bound to the credit union by) and the League Rules (which the credit union is bound to the ILCU by). We may disclose information in your application or in respect of any account or transaction of yours from the date of your original membership to authorised officers or employees of the ILCU for the purpose of the ILCU providing these services to us.The ILCU Savings Protection Scheme (SPS): We may disclose information in any application from you or in respect of any account or transaction of yours from the date of your original membership to authorised officers or employees of the ILCU for the purpose of the ILCU providing these services and fulfilling requirements under our affiliation to the ILCU, and the SPS.
- Credit Assessment: When assessing our application for a loan, the credit union will take a number of factors into account and will utilise personal data provided from:- Your application form or as part of your loan supporting documentation
– Your existing credit union file
– Credit referencing agencies such as the Irish Credit Bureau and the Central Credit RegistrarThe credit union then utilises this information to assess your loan application in line with the applicable legislation and the credit unions lending policy.
- Customer Service: To help is improve our service to you, we may use information about your account to help us improve our customer service.
- Electronic Payments: If you use our electronic payment services to transfer money into or out of your credit union account or make payments through your debit card into your credit union account, we are required to share your personal data with our electronic payment service provider.
- Legal Duty: This basis is appropriate when we are processing personal data to comply with an Irish or EU law.
- Tax liability: We may share information and documentation with domestic and foreign tax authorities to establish your liability to tax in any jurisdiction. Where a member is tax resident in another jurisdiction the credit union has certain reporting obligations to Revenue under the Common Reporting Standard. Revenue will then exchange this information with the jurisdiction of tax residence of the member. We shall not be responsible to you or any third party for any loss incurred as a result of us taking such actions.Under the “Return of Payments (Banks, Building Societies, Credit Unions and Savings Banks) Regulations 2008” credit unions are obliged to report details to the Revenue in respect of dividend or interest payments to members, which include PPSN where held.
- Regulatory and statutory requirements: To meet our duties to the Regulator, the Central Bank of Ireland, we may allow authorised people to see our records (which may include information about you) for reporting, compliance and auditing purposes. For the same reason, we will also hold the information about you when you are no longer a member. We may also share information with certain statutory bodies such as the Department of Finance, the Department of Social Protection and the Financial Services and Pensions Ombudsman Bureau of Ireland if required by law.
- Compliance with our anti-money laundering and combating terrorist financing obligations: The information provided by you in this membership application will be used for compliance with our customer due diligence and screening obligations under anti-money laundering and combating terrorist financing obligations under The Money Laundering provisions of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 , as amended by Part 2 of the Criminal Justice Act 2013 (“the Act”).
- Audit: To meet our legislative and regulatory duties to maintain audited financial accounts, we appoint an external auditor. We will allow the external auditor to see our records (which may include information about you) for these purposes.
- Nominations: The Credit Union Act 1997 as amended allows members to nominate a person(s) to receive a certain amount from their account on their death, subject to a statutory maximum. Where a member wishes to make a nomination, the credit union must record personal data of nominees in this event.
- Credit Reporting: Where a loan is granted in the sum of €500 or more, the credit union is obliged to report both personal details and credit details of the borrower to the CCR. From 1st October 2018, where a loan is applied for in the sum of €2,000 or more, the credit union is obliged to make an enquiry of the Central Credit Register (CCR) in respect of the borrower.
- Legitimate Interests: A legitimate interest is when we have a business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
- Credit Assessment and Credit Reference Agencies: When assessing your application for a loan, as well as the information referred to above in credit assessment, the credit union also utilises credit data from credit referencing agencies such as the Irish Credit Bureau and the Central Credit Registrar.Our legitimate interest: The credit union, for its own benefit and therefore the benefit of its members, must lend responsibly and will use your credit scoring information in order to determine your suitability for the loan applied for. When using the service of a credit referencing agency we will pass them your personal details and details of your credit performance.ICB are using Legitimate Interests (GDPR Article 6 (f)) as the legal basis for processing of your personal and credit information. These Legitimate Interests are promoting greater financial stability by supporting a full and accurate assessment of loan applications, aiding in the avoidance of over-indebtedness, assisting in lowering the cost of credit, complying with and supporting compliance with legal and regulatory requirements, enabling more consistent, faster decision-making in the provision of credit and assisting in fraud prevention.Please review ICB’s Fair Processing Notice which is available at http://www.icb.ie/pdf/Fair Processing Notice.pdf. It documents who they are, what they do, details of their Data Protection Officer, how they get the data, why they take it, what personal data they hold, what they do with it, how long they retain it, who they share it with, what entitles them to process the data (legitimate interests), what happens if your data is inaccurate and your rights i.e. right to information, right of access, right to complain, right to object, right to restrict, right to request erasure and right to request correction of your personal information.
- CCTV: We have CCTV footage installed on the premises with clearly marked signage. The purpose of this is for security.Our legitimate interest: With regard to the nature of our business, it is necessary to secure the premises, property herein and any staff /volunteers/members or visitors to the credit union.
- Voice Recording: Phone conversations, both incoming and outgoing, may be recorded for the purpose of verifying information and quality of service.Our Legitimate interest: To ensure a good quality of service, to ensure that correct instructions were given or taken due to the nature of our business and to quickly and accurately resolves any disputes.
- Your Consent: We will only carry out processing which is based on your consent and will cease processing once you withdraw such consent
- Marketing and Market Research: To help us improve and measure the quality of our products and services we undertake market research from time to time. This may include using the Irish League of Credit Unions and/ specialist market research companies. See section on Your Marketing Preferences.
- Art Competition: This credit union is involved with the Art Competition in conjunction with the Irish League of Credit Unions. Upon entry you will be given further information and asked for your consent to the processing of personal data. Your information is processed only where you have given consent. Where the person is under the age of 18 we ask that the parent/legal guardian provide the appropriate consent. A separate privacy notice is included in all Art Competition entry forms.
- Schools Quiz: This credit union is involved in the Schools Quiz in conjunction with the Irish League of Credit Unions. The Schools Quiz is open to entrants aged 4 to 13. Upon entry, parent/legal guardians will be given further information and asked for their consent to the processing of their child’s personal data. This information is only processed where consent has been given.
Your rights in connection with your personal information
GDPR acts to empower data subjects with enhanced rights in relation to how we use your information, including the right to:
- find out if we use your information, access your information and receive copies of your information
- have inaccurate/incomplete information corrected and updated
- object to particular use of your personal data for our legitimate business interests or direct marketing purposes. Members possess the right to opt out any anytime.
- in certain circumstances, to have your information deleted or our use of your data restricted
- in certain circumstances, a right not to be subject to solely automated decisions and where we make such automated decisions, a right to have a person review the decision
- to withdraw consent at any time where processing is based on consent.
If you have any questions as to how we use your information or if you wish to exercise any of your data rights you can contact our data protection lead in-branch, by mail to Wicklow and District Credit Union, 3 Main Street, Wicklow or by contacting 0404-69380. If you make your request electronically, we will try to provide you with the relevant information electronically.
You also have the right to complain to the Data Protection Commission or another supervisory authority. You can contact the Office of the Data Protection Commissioner at:
Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231
Postal Address: Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois.
Download our GDPR Polices
PRIVACY NOTICE – LENDING (pdf)