Unify Credit Union

Privacy Policy

PRIVACY – how we use your personal information

This Privacy Notice is to let you know how Unify Credit Union Limited (UCUL) promises to look after your personal information. This includes what you tell us about yourself, what we learn by having you as a member, and the choices you give us about what marketing you want us to send to you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.

Our Privacy Promise

We promise:

How the law protects you

As well as our Privacy Promise, your privacy is protected by law. This section explains how that works.

Data Protection Law says that we are allowed to use personal information only if we have a proper reason to do so. The law says we must have one or more of these reasons:

A legitimate interest is when we have a business or commercial reason to use your information. 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.

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 personal information for

Our reasons

Our legitimate interests

To manage our relationship with you or your business

Your consent

Keeping our records up to date

To develop new ways to meet our member needs and to grow our business

Fulfilling contracts

Working out which of our products and services may interest you and telling you about them

To develop and carry out marketing activities

Our legitimate interests

Developing products and services

To study how our members use our products and services

Our legal duty

Seeking your consent when we need to contact you

To provide advice and guidance about our products and services

 

Being efficient about how we fulfil our legal duties

To develop and manage our products and services

Fulfilling contracts

Developing products and services

To test new products

Our legitimate interests

Being efficient about how we fulfil our legal duties

To manage how we work with other companies that provide services to us and our members

Our legal duty

 

To deliver our products and services

Fulfilling contracts

Being efficient about how we fulfil our legal and contractual duties

To make and manage member payments

Our legitimate interests

Complying with regulations that apply to us

To manage charge and interest due on member accounts

Our legal duty

 

To collect and recover money that is owed to us

 

 

To detect, investigate, report and seek to prevent financial crime

Fulfilling contracts

Developing and improving how we deal with financial crime, in addition to our legal duties in this respect.

To manage risk for us and our members

Our legitimate interests

Complying with regulations that apply to us

To obey laws and regulations that apply to us

Our legal duty

Being efficient about how we fulfil our legal and contractual duties

To respond to complaints and seek to resolve them

 

 

To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance and audit.

Our legitimate interests

Complying with regulations that apply to us

Our legal duty

Being efficient about how we fulfil our legal and contractual duties

To exercise our rights set out in agreements and contracts

Fulfilling contracts

 

 

 

 

 

Groups of Personal Information

We may use many different kinds of personal information and group them together like this.

Type of Personal Information

Description

 

Financial

Your financial position, status and history

Contact

Where you live and how to contact you

Socio-Demographic

This may include details about your work or profession and nationality

Transactional

Details about your payments to and from your accounts with us

Contractual

Details of products and services we provide to you

Locational

Data we get about where you are, such as may come from your mobile phone, or the address where you connect a computer to the internet.

Behavioural

Details about how you use our products and services.

Technical

Details on the devices and technology you use

Communications

What we learn about you from letters, emails and conversations between us.

Social Relationships

Your family, friends and other relationships

Open Data and Public Records

Details about you that are in public records such as the Electoral Register and information about you that is openly available on the internet

Usage Data

Other data about how you use our products and services

Documentary data

Details about you that are stored in documents in different formats or copies of them. This could include things like your passport, driving licence or birth certificate.

Special types of data

The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:

 

    Racial or ethnic origin

 

    Heath data, including gender

 

    Criminal convictions and offences

Consents

Any permissions, consents or preferences that you give us. This includes things like how you want us to contact you and whether you prefer your correspondence in large print format.

National Identifier

A number or code given to you by a government department to identify who you are, such as a National Insurance Number

 

Where we collect personal information from

We may collect personal information about you (or your business) from these sources:

Data we collect when you use our services includes the amount, frequency, type, location, origin and recipients:

Data from third parties we work with:-

 

Who we share your personal information with

We may share your personal information with:

We may need to share your personal information with other organisations to provide you with a product or service you have chosen:

We may also share your personal information if the make-up of UCUL changes in the future:

 

How we use your information to make automated decisions

We sometimes use systems to make automated decisions based on personal information we have, or are allowed to collect from others about you or your business. This helps us to make sure our decisions are quick, fair, efficient and correct based on what we know.

Opening Accounts

When you open an account with us, we check that the product and service is relevant for you based on what we know. We also check that you or your business meets the conditions needed to open the account. This may include checking age, residency, nationality or financial position.

 

Approving Credit

We use a system to decide whether to lend money to you when you apply for a loan. This uses past data to assess how you’re likely to act while paying back any money you borrow. This includes data about similar accounts you may have had before and data from four sources:

This gives us an overall assessment and helps us to make responsible lending decisions that are fair and informed.

 

Your rights

As a person you have rights over automated decisions.

If you want to know more about these rights please contact us.

 

Credit Reference Agencies

We carry out credit and identity checks when you apply for a product or service for you or your business and use Credit Reference Agencies to help with this. If you use our services from time to time, we may also search information that the credit reference agencies have to help us manage the accounts.

We will share your information with credit reference agencies and they will give us information about you. The data we exchange can include:

We will use this data to:

We will go on sharing your personal information with credit reference agencies for as long as you are a member. This will include details about your settled accounts and any debts not fully repaid on time. If you borrow, it will include details of your repayments and whether you repay in full and on time. The credit reference agencies may give this information to other organisations that want to check your credit status. We will also tell the credit reference agencies when you settle your accounts with us.

When we ask credit reference agencies 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. You can find out more about the credit reference agencies on their websites. This includes details about:

We may need to confirm your identity before we provide products and services to you or your business. Once you have become a member of ours, we will 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 UCUL and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either 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:

We or a fraud prevention agency may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate and prosecute crime.

Fraud prevention agencies 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 kinds of personal information that we use:

Fraud Prevention

The information we have for you or your business 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 fraud prevention agencies may process your personal information in systems that look for fraud by studying patterns in 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 a fraud prevention agency decide there is a risk of fraud, we may stop activity on the accounts or block access to them. Fraud prevention agencies may also keep a record of the risk that you or your business may pose. This may result in other organisations refusing to provide you with products or services or to employ you.

Data transfers out of the EEA

Fraud prevention agencies may send personal information to countries outside of the European Economic Area (EEA). When they do there will be a contract in place to ensure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.

Sending data outside of the EEA

We will only send data outside of the EEA to:

If we transfer information to our agents or advisers outside of the EEA, we will ensure that it is protected in the same way as if it was being used in the EEA. We will use one of these safeguards:

If you choose not to give personal information

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 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 account with us. It could mean that we cancel a product or service you have with us. Any data collection that is optional will be made clear at the point of collection.

Marketing

We may use your personal information to tell you about relevant products or services. 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, or from third parties we work with. We study this to form a view of what we think you may want or need, or what may be of interest to you. This is how we decide which products or services may be relevant for you.

We can only use your personal information to send you marketing messages if we have either your consent or a legitimate interest. This is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.

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

Whatever you choose, you will still receive statements and other important information such as changes to your products and services and information as a member of UCUL, such as AGM or SGM notices.

We may ask you to update or confirm 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, regulations or structure of our business. If you change your mind you can update your choices by contacting us at any time.

How long we keep your personal information

We will keep your personal information for as long as you are a member of Unify Credit Union Limited. After you stop being a member, we may keep your data for up to 6 years for one of these reasons:

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 ensure that your privacy is protected and only use it for those purposes.

How to get a copy of your personal information

You can access your personal information by completing a Subject Access Request Form available on request from any of our branches or you can request this online by emailing info@unifycu.org.

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 of incomplete. Please contact us if you wish to do this. If you do, we will take all reasonable steps to check the accuracy and correct it where necessary.

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 retain it. This is known as the ‘right to object’ and ‘right to erasure’ or ‘right to be forgotten’.

There may be a legal or other official reason why we need to keep or use your data but please tell us if you think 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 to exercise a legal right. In this situation we would not share or use your data in other ways whilst it is restricted.

You can ask us to restrict the use of your personal information if:

If you want to object to how we use your date, or ask us to delete it or restrict how we use it, please contact us.

How to withdraw your consent

You can withdraw your consent at any time. Please contact us if you wish to do so. If you withdraw your consent we may not be able to provide certain products or services to you. If this is the case, we will tell you.

How to complain

Please let us know if you are unhappy with how we have used your personal information. Please call into your local branch and speak to one of our team or email info@unifycu.org. Alternatively you can write to the Complaints Officer, Unify Credit Union Limited, 21 Crompton Street, Wigan WN1 1BN

You also have the right to complain to the Information Commissioner’s Office. Find out more on their website https://ico.org.uk/

Data Privacy Laws will change on 25th May 2018. From this date you have the right to get your personal information from us in a format that can easily be re-used. You can also ask us to pass on your personal information in this format to other organisations.

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