Privacy Notice

We at Croí Laighean Credit Union (CLCU) take personal privacy very seriously and take steps to ensure that your data is used and stored in a secure manner. We want you to know what we do with personal information that you and others provide to us. This statement explains how we use your data and what rights you have in relation to your personal information. This Privacy Statement should be read in conjunction with Terms and Conditions.

1. Who we are

Throughout this Privacy Statement ‘we’, ‘us’, ‘our’, and ‘ours’ refers to Croí Laighean Credit Union. For more information about us, see our website at www.clcu.ie.

This notice is so that we provide you with information around the use of your data for lending or lending related purposes. This notice also applies to any person who guarantees a loan for a member of the credit union.

Croi Laighean Credit Union is committed to protecting the privacy and security of your personal data. This privacy notice describes how we collect and use personal data about you during and after your relationship with us ends, in accordance with the Data Protection Act 2018.

1. Who our Data Protection statement applies to

The data protection statement provides specific information relating to the following data subject whose Personal Data we process:

• Credit Union Members.
• Individuals who are party to or connected with any of the services we offer our members such as beneficiaries , guarantors , relations or representatives of one of our members
• Business contact details including those of our suppliers or partners.
• Members of the public and non- members who pass by and / or visit the Credit union and whose images are captured on CCTC or telephone our offices.
• Users/ visitors of our website; and
• Prospective employees of the Credit Union
• Employees of the Credit Union and certain individual’s serving as board members and volunteers of the Credit union is dealt with in a separate internal data protection notice.

2. Why do we collect your information

We gather and process personal information for several purposes and rely on several different legal basis to use that information

(a) To comply with our legal obligations

We are required to process your personal information to comply with certain legal obligations, for example:

• to report and respond to queries raised by regulatory authorities, law enforcement and other government agencies such as the Central Bank of Ireland and A Garda Siochana.
• to comply with tax regulations that require us to report the tax status of our members.
• to verify the personal information provided to us and meet our legal and compliance obligations, including to prevent money laundering, tax avoidance, financing of terrorism and fraud.
• to perform credit checks in the event you apply for a loan and to supply information to the Central Credit Register and to use the Central Credit Register when considering loan applications to determine your borrowing options and repayment capacity and/ or facilitate other lending institutions to carry out similar checks.
• to cooperate and provide information requested in the context of legal and/or regulatory investigations or proceedings.
• to keep records of communications and member account activities.
• to maintain a register of members of the Credit Union.
• to administer our internal operational requirements (including credit, compliance and risk management, system development, staff training, accounting and for audit purposes).
• to communicate with you through certain mandatory service communications such as providing notice of the AGM; and
• to undertake systems testing, maintenance and development and to ensure network and information security.

(b) To enter and perform a contract with you for the services or products which you require

To consider your application for membership of the Credit Union and to process any product/service applications which you may make, we must gather certain personal information.

To administer and manage any account you have with the Credit Union, we must process your personal information. Examples of processing include the administration of accounts, payments, deposits, lending, credit decisions. As part of this process, we may be required to pass some personal information to an intermediary or counterparty.

(c) To enable the Credit Union to function as a business

In certain circumstances, we process your personal information based on the legitimate interests of the Credit Union. In doing so, we ensure that the impact of the processing on your privacy is minimised and that there is a fair balance between the legitimate interests of the Credit Union and your privacy rights. If you disagree with your information being processed in this manner, you are entitled to exercise your right to object. Examples of situations in which your personal information is processed based on our legitimate interests, include:

• to collect due and outstanding debt which may involve passing your personal information to debt collection agencies.
• to keep records of communications, including telephone conversations, if required to evidence what has been discussed and keep a record of your instructions and to prevent or detect crime.
• to perform research and analysis aimed at improving our products, services and technologies; and
• to establish, exercise and safeguard our rights, including where necessary to take enforcement action and to respond to claims made against the Credit Union.

(d) Where you have provided consent

We use your personal information to make you aware of products and services which may be of interest to you where you have consented to us doing so and in accordance with your preferences. You can at any time withdraw that consent using the contact details below.

If you apply for a loan, we may collect and process information on your health. You will be asked for your consent to process this type of personal information.

Direct Marketing and your Personal Information

From time to time, we would like to make you aware of other products and services that we offer which may be of interest to you. We can do this by using some of the personal information we hold about you. You have a right not to receive such information. You can make changes to your marketing preferences at any time by contacting us at the address below.

Automated Processing and Decision Making and your Personal Information

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 loans assessment and anti-money laundering purposes and compliance with our legal duties in that regard.

We use systems to make automated decisions based on personal information we have – or are allowed to collect from others – about you or your organisation. When you apply for a loan, we use data from different sources to look at your ability to repay the loan. We also use information provided by your and information from third parties such as credit reference agencies. The information we process for automated lending decisions includes Income, financial statements, transaction history, salary, spending and bills, credit rating, other loans held by you.

In certain circumstances, you can object to a decision based on automated processing by contacting us at welcome@clcu.ie .

3. What information do we collect?

The information we hold about you can vary depending on the products and services you use. It will include personal information you give to us when you are applying for membership or applying for a product or service and personal information, we receive from other sources like credit referencing agencies. The categories of personal information we collect about you may include:

Categories of Personal Data

We may collect, store and use the following categories of Personal Data about you :

• Contact Data
  Includes email addresses , Phone number , Postal address and Billing address
• Identification Data
  This includes name, marital status, title, data of birth, gender, PPSN, photographs, job title and employer. It also includes background and verification data such as a copy of passports, driver’s license or utility bills as well as other information we require to comply with our obligations under anti-money laundering legislation.
• Registration Data
  This includes username and password as well as mobile phone number and security questions which are used to create and manage user accounts for secure access to our online services.
• Member Financial Data
  This includes financial data such as your account status and history, transaction data, contract data, credit checks, details of the Credit Union products being used. This also includes payment related information or bank account details and financial data received as part of the services that we offer. With loans we may also request broader information around your financial income and outgoings such as salary, occupation, accommodation status, mortgage details, other loans and debts, previous addresses, spouse, partners and we may request further information to support the purpose for the loan.
• Correspondence Data
  If you interact with us, we will record details of those interactions. For example, we will process details of phone calls, email correspondence and hard copy correspondence. This includes recording of incoming calls to the Credit Union.
• Marketing Data
  This includes your preferences in receiving marketing from us and your correspondence preferences.
• CCTV Data
  We operate CCTV cameras at the Credit Union. If you pass by and/or visit any of the Credit Union premises, your image may be recorded on CCTV.
• Call Recording Data
  We record all incoming and outgoing calls in the Credit Union to review and ensure service quality and to meet regulatory requirements.
• Recruitment Data
  If we interact with you for the purposes of any job with the Credit Union, we will collect recruitment related data such as identification data, CV data and application data as part of the recruitment process. When processing CV data, we may process certain Personal Data including the following: date of birth, employment history, skills/ experience, languages, educational history, qualifications, membership of professional associations, contact details of employer references/character references, licenses held, interests and hobbies, languages, locations, nationality, passport, eligibility to work in certain jurisdictions, salary expectations. As part of processing Recruitment Data, we process interview/screening answers.
• Web Data
  When you interact with us online, we will automatically collect data about your use of our services, including data on the type of device you’re using, its IP address, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of Website use. Where possible, this information is collected at an aggregate level, and your identity data is not stored as part of this technical data. Web Data includes cookies and web beacons.
• Social Media Data
  Social media data is collected when you interact with our social media channels through shares, likes, comments, mentions, follows, impressions or clicks on content
• Special Categories of Personal Data
  When we provide our services, we may process special categories of Personal Data. Under the GDPR special category Personal Data includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. The special category Personal Data that may be processed by the Credit Union include:
• Health Data
  When you are taking out a loan the Credit Union may ask you to make a health declaration to obtain insurance cover for the loan. While loan Insurance is free to members, it is a requirement of our loan terms that our members take out insurance on unsecured loans. We process this information with your explicit consent.
• Other Special Category Data
  Special categories of data relating to political opinions, religious or philosophical beliefs, or trade union membership, or data concerning a natural person’s sex life or sexual orientation may be inferred from information you provide such as when you make payments to a religious or political organisation. Such information is incidental to the purposes of processing, and we do not further process this information for any other purpose. From time-to-time members may provide special category data to us to support a loan application. For instance, members may be applying for a loan to finance a medical procedure and may furnish information relating to the procedure. While we may ask generally for information to support a loan application, we never ask for medical information or other special category data in these circumstances. It is our policy if it is provided to us to return such information to the member.

4. How do we collect your information?

We collect personal information from several sources, including:

• information we receive directly from you or from a person acting on your behalf.
• information we obtain from third parties such as credit reference, debt recovery or fraud prevention agencies, which may have originated from publicly accessible sources.
• information we obtain from your interaction with us on our website and mobile application(s) and e-signature facility.
• information that we gather from publicly available sources such as the Internet.

5. How we use your information?

We use and share your data where:

• You have agreed or explicitly consented to the using of your data in a specific way. You may withdraw consent at any time, where such processing is based on consent.
• Use is required in relation to a service or a contract you have entered — e.g. the provision of financial services.
• Use is necessary because we must comply with a legal obligation — e.g. complying with ‘Know Your Client’ obligations and reporting to regulatory authorities and law enforcement.
• Use is necessary to protect your ‘vital interests’ in certain circumstances.
• Use is for our ‘legitimate interests’, such as managing our business — e.g. managing our loan book
• To inform you of our services.

6. How we keep your information safe?

We know that you care about how your information is used, stored, and shared. We at Croí Laighean Credit Union take appropriate measures that comply with Irish and EU Laws, including the General Data Protection Regulations. Our IT systems meet international standards of security, while physical file storage is subject to safeguards, such as secure premises and filing systems.

Use of third parties

In order that we may provide you with our services, we may share your information with:

• Your authorised representatives.
• Third parties with whom we need to share your information to facilitate transactions.
• Third parties with whom you ask us to share your information.
• Third parties in relation to the recovery of debts
• Service providers who provide us with support services.
• Statutory and regulatory bodies.
• Credit reference agencies.
• Business partners

Member Personal Current Account

If we issue you a debit card, Transact Payments Malta Limited (which is an authorised e-money institution) will also be a controller of your personal data. In order for you to understand what they do with your personal data, and how to exercise your rights in respect of their processing of your personal data, you should review their privacy policy which is available at http://currentaccount.ie/files/tpl-privacy-policy.pdf

7. How long we hold your data?

While we do not wish to hold your information for longer than is required, we are subject to legislative and regulatory rules that we must follow. Our policy is to hold your information only for as long as is required by such rules.

8. Implications of not providing your data

If you do not provide information, we may not be able to provide services or maintain services.

9. Your rights in relation to your information

Data Protection legislation confers specific rights on individuals. This Privacy Statement is intended to inform you of these rights. Specifically:

• Right of access to your information and copies of your information
• Right to have your data rectified if found to be incorrect
• Right to be forgotten
• Right to object to a particular use of your information
• Right to restrict the use of your information, in certain circumstances

10. How to exercise your rights

To exercise your rights, we at Croí Laighean Credit Union have implemented a Subject Access Request process.

This can be initiated by contacting our Data Protection Officer at dpo@clcu.ie or call us at: 1800 23 24 25.
Postal Address: O’Connell Square, Edenderry, Co Offaly

If we are unable to deal with your request within one calendar month, we may in certain circumstances due to the complexity of the request, extend this period by up to two further months.

You also have the right to complain to the Data Protection Commission at:

Data Protection Commission,
Address: 6 Pembroke Row, Dublin 2, D02 X963. Ireland
Tel: +353 1 765 01 00 / 1800 437 737

11. Supervisory Authority

The Data Protection Commission in Ireland may be contacted using the contact details below if you have any concerns or questions about the processing of your Personal Data.

Contact Details.
Online Form: https://forms.dataprotection.ie/
Contact Address: 6 Pembroke Row, Dublin 2, D02 X963. Ireland
Tel: +353 1 765 01 00 / 1800 437 737

12. Amendments to Privacy Notice

We will update our Data Privacy Notice from time to time. Any updates will be made available on our website at Privacy Notice | Croí Laighean Credit Union,