Privacy Policy

Looking after your information

Your right to privacy is important to us.   We take the security of your information seriously and have strict policies and processes in place to ensure it remains safe.   This privacy policy describes the way we collect your information, how we use it and why.

Liverpool Community Credit Union Ltd, will manage your data in line with the requirements of the Data Protection Act 1998 and the provisions of 2018 General Data Protection Regulation (GDPR)

Liverpool Community Credit Union Ltd will act as the ‘data controller’ for your personal data if you apply for or hold an account or service with us.   Under the Data Protection Act and GDPR provisions the ‘data controller’ is responsible for ensuring that your information is lawfully and properly processed.   This means that you are entitled to know how we intend to use any information you provide.   You can then decide whether you want to give it to us in order that we may provide the product or service that you require.

Where we obtain your Information

Your personal information will be held securely in our system so that we can manage your relationship with us.   This will include information you provide when you apply to us and any additional information provided by you or others in various ways including

  1. In applications, emails and letters, during telephone calls and conversations in the credit union offices or when registering for services through the credit unions website
  2. From analysis (for example, the amount, frequency, origin and recipient) of your payments either to or from you, including the creation of profiles used to uniquely identify you when you use our on-line, mobile and telephone services which are used to help us combat fraud or other illegal activity; and
  3. Information the credit union receives from or through other organisations (for example, credit reference agencies), whether in the course of providing products or services to you or otherwise, and from information we gather from your use of our internet service

We will not retain your information for longer than is necessary for the maintenance of your account, or for legal or regulatory requirements.

Central Member Database

We hold member information on a central member database which is also the register of our members.   Individual account statements and communications will always be sent to the address of the first named account holder associated to the account in question.

How we share your Information

We may share the personal information we hold about you within the credit union for the following administrative activities

  1. Providing you with products and services and notifying you about either important changes or developments to the features and operations of those services
  2. Responding to your enquiries or complaints
  3. Facilitating the secure access to on-line platforms

And for the following data sharing activities

  1. Updating, consolidating and improving the accuracy of our records
  2. Undertaking transactional analysis
  3. Arrears and debt recovery activities
  4. Testing new systems and checking upgrades to existing systems
  5. Crime detection, prevention and prosecutions.
  6. Evaluating the effectiveness of marketing, and for market research and training
  7. Assessing lending and insurance risks

By sharing this information, it enables us to better understand your needs and to run your accounts in an efficient way.    Your data may be used for other purposes for which you give your specific permission, or in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998 and the provisions of 2018 General Data Protection Regulation.

When we may share your Information

We will treat your personal information as private and confidential, but may share it with each other and disclose it outside the credit union if;

  1. Allowed by this agreement
  2. You consent
  3. Needed by sub-contractors to help us manage your records
  4. HM Customs or other authorities require it
  5. The law, regulatory bodies or the public interest permits it
  6. Required by us or others to investigate or prevent crime
  7. Needed by market research companies to assist us in providing better products or services for you
  8. Any other parties connected with your account need it
  9. Required as part of our duties to protect your account for example to the Financial Services Compensation Scheme.

Using your Information to prevent Terrorism or Crime.

The government also requires us to screen applications that are made to us to ensure we are complying with the international fight against terrorism and other criminal activities.  As a result of this we may need to disclose information to government bodies.

Joint Applicants

If you give personal information about someone else, then you should not do so without their permission.   When information is provided by you about someone else, or someone else discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this privacy notice.

How we manage Sensitive Personal Data

The Data Protection Act defines certain information as ‘sensitive’ (racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences).   We will only use this information to provide the service you require, and we will ask for your explicit consent.  As a member there may be times when you give us sensitive data

How we use Credit Reference Agencies

Credit Reference Agencies collect and maintain information about consumers’ and businesses’ credit behaviour.   This includes electoral register, fraud prevention and credit information – including details of previous applications and the conduct of your accounts – and public information such as County Court Judgements, decrees and bankruptcies.   The information that this credit union and other organisations provide to credit reference agencies about you, or your financial associates, may be provided to other organisations and used by them and us to;

  1. Help make decisions, for example when
  • Checking details on applications for credit, and credit related facilities
  • Managing credit or credit related facilities
  • Recovering debt
  • Checking details of job applicants and employees
  1. Detect and prevent crime, fraud and money laundering
  2. Check your credit history
  3. Verify your identity, if you or someone financially linked to you, applies for services
  4. Trace your whereabouts; and
  5. Undertake research, statistical analysis and system testing

If your credit union needs to make a credit decision when you apply for a credit related product or service your records may be searched along with those of anyone financially associated with you such as a spouse or partner.   The CRA will keep a record of this search and place a ‘footprint’ on your credit file, whether or not the application proceeds.

Debt Recovery Process

We may give details of your account and how you conduct it to the credit reference agencies including if you borrow and do not repay in full and on time.   If you fall behind with your payments and a full payment or satisfactory proposal is not received within 28 days of a formal demand being issued, then a default notice may be recorded with the CRA’s.   Any records shared will remain on file for 6 years after your account is closed, whether it has been settled by you or as a result of a default.   Other organisations may see these searches and updates if you apply for credit in the future, and these may affect your ability to borrow from other lenders.

In addition, we may authorise a third party such as a solicitor or a debt collection agency to act on our behalf in the recovery of the debt.   If we decide to take this action, we will inform you before we disclose your details to them.  If we are unable to locate you to discuss the situation, we may pass your details to a tracing agency.

Joint accounts and credit reference agencies.

If you apply for or hold an account in joint names, or tell us you have a financial associate, a financial association will be created between your records.    This means that your financial affairs may be treated as affecting each other.   These links will remain on your and their files until such time as you or your partner is successful in obtaining a disassociation with the CRA’s to break that link.  You must be sure that you have their agreement to disclose information about them.

You have a right to apply to the credit reference agencies for a copy of your file.   We carry out most of our credit searches uses Experian, but details of how you run your account may be disclosed to all the credit reference agencies.   The information they hold may not be the same and there may be a small fee you have to pay to each agency you apply to.

Using Fraud Prevention Agencies

We have systems that protect our members and ourselves against fraud and other crime.   Member information can be used to prevent crime and trace those responsible.   We will share your personal information from your application with fraud prevention agencies.   If false, or inaccurate information is provided, and fraud is identified, details of this fraud will be passed to these agencies.   Law enforcement agencies may access and use this information.   We and other organisations may also access and use this information to prevent fraud and money laundering.

How we check your identity

We may ask you to provide physical forms of identity verification when you open your account, and/or we provide services to you.   Alternatively, we may search Credit Reference Agency files in assessing your application.   The agency may give us other details and information from the electoral register to verify your identity.   The agency keeps a record of this search whether or not your application proceeds.   Our search is not seen or used by lenders to assess your ability to obtain credit.

Using your details for service contact

Making sure we deliver excellent customer service is very important to us and to do this various methods of communication may be used when sending you information about your account.   Most of the time you will be contacted by letter or telephone, but you may also be sent be sent updates or messages at any time.

Recording Telephone Calls

We may monitor or record phone calls with you in case we need to check we have carried out your instructions correctly, to resolve queries or issues, for regulatory purposes, to help improve our quality of service, and to help and prevent fraud or other crimes.   We also operate CCTV in our offices.

Obtaining a copy of your information

Under the Data Protection Act you have the right of access to your personal data.   The Act allows us to charge a fee of £10 for this service.   If anything is inaccurate or incorrect, please let us know and we will correct it.

Cookies

With regards to the new requirements on Cookies following the revision of the e-Privacy Directive, the Credit Union is working towards implementing the new requirements in line with guidance from the Information Commissioners Office.  To make using our Site as straightforward as possible and to improve the service we offer you, we use cookies.

What are Cookies?

Cookies are text files that web servers can store on your computer’s hard drive when you visit a website.   There are two main types

  • Transient (or per session) cookies

These only exist for your site visit and are deleted on exit.   They recognise you as you move between pages.   These cookies help maintain security

  • Persistent or permanent cookies.

These stay on your machine until expiry or deletion.   Many are built with automatic deletion dates to ensure your hard drive doesn’t get overloaded.   These cookies often store and re-enter your log in information, so you don’t need to re-enter your membership details.

Additionally, cookies can be first or third-party cookies.   First party cookies are owned and created by the website you’re viewing – in this case by the credit union.   Third party cookies are owned and created by an independent company, usually a company providing a service to the website owners.   In our case, third party cookies provided from this Site are still subject to the provisions set out below.

What we use Cookies for

  • Gather customer journey information across our sites
  • Ensure your privacy in our secure site
  • Temporarily store details input into our calculators, tools, illustrations and demonstrations.

We use both our own (first party) and partner companies (third party) cookies to support these activities.

We don’t use cookies to track people’s internet usage after leaving our sites

Services requiring enabled cookies

Some of our services require cookies in your browser to view and use them and to protect your financial and personal information

Changing your cookie settings

You are not obliged to accept cookies that we send you and you can modify your browser so that it will not accept cookies.   To enable or disable cookies, follow the instructions provided by your browser (usually located within the Help, Tools or Edit facility).

Please note that should you choose to set your browser to disable cookies, you may not be able to access secure areas of this site, for example any on-line accounts you may hold.

Amendments

The credit union reserves the right at its sole discretion to amend this privacy statement at any time and you should regularly check this privacy statement for any amendments.

Liverpool Community Credit Union is authorised by the Prudential Regulation Authority & regulated by the Financial Conduct Authority & the Prudential Regulation Authority. FRN: 213404