Privacy Policy

WHO WE ARE

CREDIT UNION SOLUTIONS LTD
We provide back office administration to Credit Unions in London and the South East of England. Currently they are:

M for Money Credit Union
Thamesbank Credit Union
Hertsavers Credit Union

We provide comprehensive customer service supporting potential and existing member enquiries. In addition, we undertake all aspects of loan applications, share withdrawals, deposits, new membership applications, marketing, accounting and debt recovery.

If you have any questions, or want more details on how we use your personal information, you can ask us by contacting us through our secure “contact us” form on our website www.cus.coop or by calling us on 020 8573 8010

OUR PRIVACY PROMISE

We promise:

• To keep your data safe and private
• Not to sell your data
• To allow you to manage your marketing choices at any time

HOW WE USE YOUR PERSONAL INFORMATION

In order to provide you with products and services we need to collect, use, share & store personal and financial information about you. This includes information which we:

• Obtain from you or third parties, such as employers, credit referencing agencies (who may check the information against other databases – public or private- to which they have access), or fraud prevention agencies. This information may come from your interactions with us or with them.
• Learn from the way in which you deposit or withdraw funds from your account or from your borrowing and repayment history.

WHAT WE USE YOUR PERSONAL DATA FOR

You authorise us to process and disclose information that is provided by you or that we obtain from third parties for the purposes of:

• Maintaining your Credit Union Account;
• Assessing and identifying products and services;
• Assessing loan applications;
• Detecting and preventing crime (including money laundering);

WHAT PERSONAL INFORMATION WE OBTAIN

The personal information and documentation that we may obtain and store includes the following:

• Name and Addresses;
• Telephone Numbers and E mail addresses;
• National Insurance number;
• Date of birth;
• Gender;
• Bank Account details;
• Employment details;
• Next of kin details;
• Account balances and transaction history;
• Copies of documentation to prove your age, address or income. i.e. passport, utility bill and bank statements;
• Telephone recordings;
• Copies of any letters and emails to us.

Where you provide personal and/or financial information about others (such as dependants or partners) you confirm that you have their consent or are otherwise entitled to provide this information to us and for it to be used in accordance with the agreement.

HOW THE LAW PROTECTS YOU

In addition to our privacy promise, your personal information is protected by law.

Data Protection law says that we are allowed to use and process personal information only if we have a reason to do so. This includes sharing your information with third parties. The law says that we must have one or more of the following reasons:

• To fulfil our contract to you by managing your account(s);
• To carry out regulatory checks and meet our obligations to our regulators;
• To protect ourselves against harm to our rights and property;
• To prevent and detect fraud, money laundering and other crimes;
• When there is a legitimate interest to do so;
• When you consent to it.

A legitimate interest is when we have a business or commercial reason to use your information. But even then it must not unfairly impact your right to privacy. Below is a list of all the ways in which we may use your personal information and basis under which it is being used:

What we use your Personal Information for:	Our Reasons:	Our Legitimate Interests:
To manage our relationship with you To develop & carry out marketing activities To identify the most appropriate products and services.	Your consent Fulfilling our contract to you Our legitimate interests Our legal duty	In order to keep our records and your accounts up to date. Developing products and services. Seeking your consent when we need to contact you. In order to fulfil our legal duties.
To develop and manage our products and services. Managing our relationship with our subcontractors that provide services to our members.	Fulfilling our contract to you. Our legitimate interests Our legal duty.	Developing products and services Identifying members for new products and services. In order to fulfil our legal duties.
To make and manage member payments and receipts. To manage fees, charges and interest on member accounts. To collect and recover money that is owed to us.	Fulfilling our contract to you. Our legitimate interests Our legal duty.	In order to fulfil our legal duties. To comply with regulations that apply to us
To detect, investigate and report on suspicious activity to prevent financial crime. To obey laws and regulations that apply to us. To respond to and resolve complaints.	Fulfilling our contract to you. Our legal duty. Our legitimate interests.	In order to efficiently deal with financial crime and to fulfil our legal duty to do so. In order to comply with regulations that apply to us.
To run our business in a proper and efficient way. Including managing our financial position, business planning, communications and audit.	Our legitimate interests Our legal duty	In order to comply with regulations that apply to us. In order to efficiently fulfil our legal and contractual duties.

WHERE WE COLLECT PERSONAL DATA FROM

We collect personal information about from the following sources:
Data you give to us:

• When you apply for membership;
• When you apply for a loan;
• When you make a share withdrawal;
• When you talk to us on the phone;
• In emails and letters you send to us.

Data we collect when you use our services:

• Payment and transactional data;
• Savings history;
• Loan history.

Data from third parties

• Credit referencing agencies;
• Payroll service providers;
• Government and law enforcement agencies

WHO WE SHARE YOUR PERSONAL DATA WITH

We may share your personal information with the following companies in order to fulfil our obligations to you or when we are required to do so either by our regulator or by law:

• Credit referencing agencies;
• Agents and advisors who we use to help run your accounts and services and collect what you owe;
• Payroll service providers;
• HM Revenue and customs;
• Fraud prevention agencies;
• Companies you ask us to share your information with.

A full list of our third party subcontractors can be found on our website.

HOW LONG DO WE KEEP YOUR INFORMATION

We are required to keep records for a certain period of time. Some of these requirements are legal requirements, some are contractual and some are requirements by our regulator. Below sets out the retention period for all information we hold on our members.

YOUR RIGHTS

Membership Records	Required By	Retention Period
Register of Members (Including all data provided on membership application forms)	Cooperative and Community Benefit Societies Act 2014	Permanently
Membership Share and Loan Register (including transactions, balances and forms)	Cooperative and Community Benefit Societies Act 2014	Permanently
Register of bad debts written off	FCA/PRA	Permanently
Complaints	FCA/PRA	7 Years
Call recordings		12 months digitally only
Anti Money Laundering Reports	MLR 2007	7 Years

You have the right to request:

• Access to the personal data we hold about you (usually free of charge in most cases);
• The correction of your data when incorrect, incomplete or out of date;
• That we stop using your personal data for direct marketing even if you have given consent for us to do so in the past;
• Withdrawal of your consent to process or store your personal information (provided we have no overriding legitimate interest, legal or contractual obligation to maintain these records for example you have an outstanding debt with us)

You have the right to request a copy of any information we hold about you or have that information corrected if inaccurate. To make such a request or to withdraw consent to us using your personal information please contact:

Credit Union Solutions,Bungalow, Pinkwell Lane, Hayes, Middx, UB3 1PE or email admin@cus.coop

If we do not action your request we will explain the reasons for our refusal.

Legitimate Interests – In cases where we are processing your data on the basis of legitimate interest, you can ask us to stop. We must then do so unless there is an overriding reason to continue processing your personal data. In this instance we will inform you of the reason.

Direct Marketing – You have the right to stop the use of your personal data for marketing through all channels. We must always comply with your request. You can ask us to stop using your personal data for direct marketing by telephoning us on 020 8573 8010 by emailing admin@cus.coop or by writing to us Credit Union Solutions, Bungalow, Pinkwell Lane, Hayes, Middx, UB3 1PE

Please note that you may still receive communications for a short period after changing your preferences until we have fully updated our systems.

CONTACTING THE REGULATOR

If you feel that your data has not been handled correctly or if you are unhappy with our response to any requests you have made to us in relation to the use or accuracy of your personal information then you have the right to lodge a complaint with the Information Commissioners Office (ICO)

You can contact them by calling 0303 123 1113

Or you can go online to www.ico.org.uk/concerns