WHAT IS THE PURPOSE OF THIS DOCUMENT?
First Defence Finance & Plane Saver Credit Union Ltd are 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, in accordance with the General Data Protection Regulation (GDPR).
This notice applies to:
All Third Parties and Suppliers with whom we have dealings in the ordinary course of our business including those individuals with whom we send marketing information regarding
Any reference to ‘we’, ‘us’, ‘our’, ‘the company’ shall mean Plane Saver Credit Union Ltd.
Any reference to ‘you’ or ‘Data Subject’ shall mean any individual receiving this notice for whom we hold personal data.
This Privacy Statement does not include information relating to the retention of data on limited companies as such data is not incorporated within the provisions of GDPR.
This Privacy Notice also applies to our website: https://planesavercu.co.uk/
In many circumstances we hold your data as a “Data Controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice. In some circumstances we may acquire or handle your data as a ‘Data Processor’ which means we have been asked to handle your data by a third party other than yourself and do not directly store your data.
We may update this notice at any time.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
DATA PROTECTION PRINCIPLES
We will comply with data protection laws including GDPR. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT CLIENTS/ MEMBERS
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
There are “special categories” of more sensitive personal data which require a higher level of protection.
We will collect, store, and use the following categories of personal information about you:
Financial; your financial position, status and history.
Contact; where you live and how to contact you (telephone numbers / email addresses).
Socio-Demographic; details about your work or profession, nationality, education and where you fit into general social or income groupings.
Transactional; details about payments to and from your accounts with us, and insurance claims you make.
Contractual; Details about the products or services we provide you.
Locational; data we get about where you are, such as may come from your mobile phone, the address where you connect a computer to the internet, or a shop where you buy something with your card.
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; public details about you such as the electoral register and information that is openly available on the internet.
Usage data; other data about how you use our products and services.
Documentary data; passport, drivers licence, birth certificate for example.
Date of birth.
Marital status and dependants.
National Insurance number.
Bank account details, payroll records and tax status information.
Salary, annual leave, pension and benefits information.
Location of employment or workplace.
We also record and monitor telephone calls and any information you provide to us in telephone conversations will be recorded and stored electronically.
WHY WE HOLD INFORMATION ON CLIENTS
It is necessary for us to retain data on clients in order for us to fulfil our contractual obligations and we must hold data for our legitimate business needs.
We will only retain data which we reasonably require and for a period which is reasonably necessary.
We will not disclose your data to a third party unless you have consented for us to do so or we are otherwise required to do so either contractually, for our legitimate interests or under another law or enactment.
Disclosure will often be necessary during the application process and typically we will be required to disclose information to:
HM Revenue & Customs, regulators and other authorities;
UK Financial Services Compensation Scheme
Credit Reference Agencies (For additional information please visit: https://www.transunion.co.uk/crain)
Fraud Prevention Agencies
Companies you ask us to share data with
HOW IS CLIENT PERSONAL INFORMATION COLLECTED?
We collect personal information about clients from clients themselves when we receive new enquiries and new engagements. We may sometimes collect additional information from third parties such as credit reference agencies, social networks, fraud prevention agencies, payroll providers, public sources, government and law enforcement agencies. This may include ID verification and bank account checks. For business clients we may obtain further information from Companies House if necessary.
Credit rating agencies are commonly used to process credit applications and they will provide information to us about you. These details might include your financial history, check your identity, trace and recover debts and prevent criminal activity.
Client data is stored on our various Customer Relationship Management systems (CRMs). Further information can be requested from our head office should you require further information on the systems we use. Call recordings are stored on our cloud based system and are stored in the UK.
HOW WE WILL USE INFORMATION ABOUT CLIENTS
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:
1. Where we need to protect your interests, (or someone else’s interests).
2. Where it is needed in the public interest, (or for official purposes).
Situations in which we will use your personal information
We need all the categories of information in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
Administering the contract we have entered into with you.
To assess your suitability for a loan and/or savings account with us and process your application(s).
Business management and planning, including internal and external accounting and auditing.
Dealing with legal disputes involving you.
To prevent fraud and financial crime.
Record basic information about you on a register of members.
Deal with your account(s).
Carry out credit checks and to obtain and provide credit references.
Undertake statistical analysis, to help evaluate the future needs of our members and to help manage our business.
To send you statements, new terms & conditions, changes to your account(s) and to notify you of our AGM.
To market other products or services which we offer which may be of interest to you.
To advise you of company opportunities or promotions.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
Based on data you have provided to us or data we have acquired from third parties, we may make decisions regarding pricing of products or tailoring other products or services. We may also use the data to detect fraud, when opening accounts or approving credit.
In certain circumstances listed above, we hold your data in order to market other services to you. We have a legitimate business interest in retaining your data for this purpose but you may ‘opt out’ of receiving marketing communications from us.
We may exchange your personal information if all, or substantially all, our assets are merged or acquired by a third party, or we expand or re-organise our business, in which case your personal information may form part of the transferred or merged assets or we may need to transfer your information to new entities or third parties through which our business will be carried out.
We will also process your information for the purposes of recovering debts owed to us by you.
If you fail to provide personal information
If you fail to provide certain information when 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 personal information for the purpose for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original 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.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
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:
1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations.
3. Where it is needed in the public interest.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
In certain circumstances we have legal obligations to process your data without your consent, for instance where we share data with law enforcement agencies, fraud prevention agencies and credit reference agencies as required.
These third parties may use your information to confirm your identity, help prevent fraud and money laundering, to detect, investigate, prevent or prosecute crime. Third party’s agencies may keep your data from different lengths of time to us depending on their legitimate interests in retaining the data.
THE KIND OF INFORMATION WE HOLD ABOUT INDIVIDUALS OTHER THAN CLIENTS AND HOW THIS DATA IS USED
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
During the course of our day to day business we acquire information regarding individuals other than our Clients and we will retain this data where we have a legitimate business reason to do so.
Typically, we acquire personal data on individuals other than our clients in the following circumstances:
Where individuals have made enquiries with us regarding possible services but have not subsequently become clients of the business;
Where we have dealt with individuals in the capacity as suppliers of services to the Company;
Where we have regular business-related dealings with you.
Where we have been provided with details of beneficiaries to insurance policies by a client, this information will be stored confidentially and will not be used for any other purpose.
In many circumstances the extent of the data we hold is limited and may be publicly available by way of other websites but usually the information we will retain is limited to:
· Contact information including but not limited to email addresses, contact telephone numbers, business addresses and in some cases personal addresses.
We have a legitimate business interest in retaining this data on the basis that we must retain some personal data on third parties and suppliers in the ordinary course of business. We may also use this data to send marketing information to you in respect of promotions, events or other updates relating to us. We have a legitimate interest in retaining your data for this purpose however you have the right to ask us to erase or rectify your data and the right to opt out of receiving marketing information.
In respect of data on beneficiaries, we are processing that data on behalf of any client who has nominated the individual as a beneficiary to any policy. We will not use that data other than for the purpose for which the data was provided. It is the responsibility of our client to provide the beneficiary with a copy of this Privacy Notice.
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
1. Where we have notified you of the decision and given you 21 days to request a reconsideration.
2. Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
The automated lending decision system we use looks at your credit score alongside information such as:
The amount applied for;
Your income and your expenditure;
Your history of repaying debts;
The level of debt you already hold;
The number and value of County Court Judgments (CCJ’s) you have;
The number of accounts you have that are in default;
Public information such as the insolvency service;
Whether or not you are bankrupt;
Members have the right to have the decision reviewed by a member of staff, express their point of view and challenge the decision thereafter.
In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). Where you take banking services from us we may also make periodic searches at CRAs to manage your account with us.
To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
Assess your creditworthiness and whether you can afford to take the product;
Verify the accuracy of the data you have provided to us;
Prevent criminal activity, fraud and money laundering;
Manage your account(s);
Trace and recover debts; and
Ensure any offers provided to you are appropriate to your circumstances.
We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.
When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application, or telling us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail at https://www.transunion.co.uk/crain. CRAIN is also accessible from each of the three CRAs – clicking on any of these three links will also take you to the same CRAIN document: Transunion https://www.transunion.co.uk/crain
We may have to share your data with third parties, including third-party service providers and other entities in the group.
We require third parties to respect the security of your data and to treat it in accordance with the law.
Your data is stored on our CRM system. The servers for these systems are based inside the EU. Where data is saved outside of the EU we have ensured that the data is stored in compliance with GDPR.
We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information. Although we do not directly send information to any country outside of the EU, there may be times when we need to. For example, when complying with international tax regulations and reporting personal information to HMRC. HMRC may transfer information to tax authorities in countries where you or a connected person may be tax resident.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group.
The following third-party service providers process personal information about you for the purpose of assisting us in performing our contract with you;
Solicitors and/or debt recovery agents
Credit check/reference agencies (For additional information please visit: https://www.transunion.co.uk/crain
Fraud prevention agencies
Financial Conduct Authority (FCA)
Financial Services Compensation Scheme (FSCS)
Third parties who assist in confirming your identity for the purpose of money laundering legislation
If you apply for insurance through us, we may pass your personal details to the insurer and onto any reinsurers. If you make an insurance claim, information you give us or the insurer may be put on a register of claims.
How secure is my information with third-party service providers and other entities in our group?
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies and GDPR. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal information with other third parties, for example IT/System suppliers. We may also need to share your personal information with our regulators in order to be compliant with the respective financial laws.
We have put in place measures to protect the security of your information. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
The transmission of information via the internet is not completely secure. We cannot guarantee the security of your data transmitted online and transmission is made at your own risk. If you communicate with us by email then you assume the risks of such communications being intercepted, not received or delivered or are received by individuals other than the intended recipient.
How long will you use my information for?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
In respect of Client data, we will typically hold data relating to your instructions for a period of 7 years after your loan is paid off and/or we receive instructions to close your savings account. The reason for this is that the Limitation Act 1980 typically provides that legal proceedings for breach of contract or negligence can be brought up to 6 years after the events. We therefore have a legitimate business interest in retaining the data should any subsequent legal proceedings ensue.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Bernard Scotland-Rose in writing.
Please note that where you ask us to erase, correct, object to process or seek to restrict our processing of data we may refuse your request where we have a legal obligation, contractual or other legitimate business interest to refuse your request. If we refuse your request then we will notify you of this refusal and you will have the right to appeal.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact Bernard Scotland-Rose. BernardScotland-Rose@planesaver.co.uk
Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
DATA PROTECTION MANAGER
We have appointed a Data Privacy Manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact Bernard Scotland-Rose by emailing BernardScotland-Rose@planesaver.co.uk. Mr Scotland-Rose is the data privacy manager.
In addition, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues by writing to;
Information Commissioner’s Office
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CHANGES TO THIS PRIVACY NOTICE
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.
CONTACT AND FURTHER INFORMATION
If you have any questions about this privacy notice, please contact Bernard Scotland-Rose by emailing BernardScotland-Rose@planesaver.co.uk.
If you have any questions or wish to submit a complaint then please submit this to:
Plane Saver Credit Union Ltd
The Barn, Manor Lane,
You have the right to make a complaint to the Information Commissioners Office or such other regulatory body or supervisory authority as may be appointed from time to time. If you make a complaint then we will respond to let you know how your complaint will be handled.