General Enquiries: 020 7561 1786 or Email: info@credit-union.coop      |       CU Loan Repayment Issues Only: 020 3763 8397  or Email: loansupport@credit-union.coop

Privacy Notice

Introduction

We are committed to protecting our members’ privacy. The credit union requires any information marked as mandatory for membership to either meet legal obligations or to enable us to perform our contract with you. Where you are not able to provide us with this information, we may not be able to open an account for you. Where we request further information about you not required for these reasons, we will ask you for your consent.

How we use your personal information

The Credit Union may process, transfer and/or share personal information in the following ways:

 

For legal reasons

  • confirm your identity
  • perform activity for the prevention of financial crime
  • carry out internal and external auditing
  • record basic information about you on a register of members

For performance of our contract with you 

  • deal with your account(s) or run any other services we provide to you;
  • consider any applications made by you;
  • 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 (including changes to this privacy statement), information about changes to the way your account(s) operate and notification of our Annual General Meeting.

 

For our legitimate interests

  • recover any debts owed to us

 

With your consent 

  • maintain our relationship with you including very limited marketing and market research (if you agree to them)

Sharing your personal information

We will disclose information outside the credit union:

  • to third parties to help us confirm your identity to comply with money laundering legislation
  • to credit reference agencies and debt recovery agents who may check the information against other databases – private and public – to which they have access to
  • to any authorities if compelled to do so by law (e.g. to HM Revenue & Customs to fulfil tax compliance obligations)
  • to fraud prevention agencies to help prevent crime or where we suspect fraud;
  • to any persons, including, but not limited to, insurers, who provide a service or benefits to you or for us in connection with your account(s)
  • to our suppliers in order for them to provide services to us and/or to you on our behalf
  • to anyone in connection with a reorganisation or merger of the credit union’s business
  • other parties for marketing purposes (if you agree to this)
  • a bank account checking service with your consent

Where we send your information

While countries in the European Economic Area all ensure rigorous data protection laws, there are parts of the world that may not be quite so rigorous and do not provide the same quality of legal protection and rights when it comes to your personal information.

The credit union does not directly send information to any country outside of the European Economic Area, however, any party receiving personal data may also process, transfer and share it for the purposes set out above and in limited circumstances this may involve sending your information to countries where data protection laws do not provide the same level of data protection as the UK. For example, when complying with international tax regulations we may be required to report personal information to the HM Revenue and Customs which may transfer than information to tax authorities in countries where you or a connected person may be tax resident.

 

Retaining your information

The credit union will need to hold your information for various lengths of time depending on what we use your data for. In many cases we will hold this information securely for a period of time after you have left the credit union.

 

Credit rating agencies

In order to process credit applications you make we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.

We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates. This may affect your ability to get credit.

The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail on:

 

Your Rights

Your rights under data protection regulations are:

  • The right to access
  • The right of rectification
  • The right to erasure
  • The right to restrict processing
  • The right to data portability
  • The right to object to data processing
  • Rights related to automating decision-making and profiling
  • Right to withdraw consent
  • The right to complain to the Information Commissioner’s Office 

Your rights explained;

 

Right to Access  

You have the right to access your personal data and details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. You can access your personal data by visiting login.asp when logged into the members secure area of our website.

 

The right to rectification

You have the right to have any inaccurate personal data about you corrected and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

 

The right to erasure 

In some circumstances you have the right to the erasure of your personal data without undue delay.

Those circumstances include: 

  • the personal data is no longer needed for the purpose it was originally processed
  • you withdraw consent you previously provided to process the information
  • you object to the processing under certain rules of data protection law
  • the processing is for marketing purposes
  • the personal data was unlawfully processed
  • However, you may not erase this data where we need it to meet a legal obligation or where it necessary for the establishment, exercise or defence of legal claims.

 

The right to restrict processing

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are:

  • you contest the accuracy of the personal data;
  • processing is unlawful but you oppose erasure;
  • we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and
  • you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data.

We will only otherwise process it:

  • with your consent;
  • for the establishment, exercise or defence of legal claims; or
  • for the protection of the rights of another natural or legal person; 

The right to object to processing

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the data is necessary for the purposes of the legitimate interests pursued by us or by a third party.

If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

 

The right to data portability

To the extent that the legal basis for our processing of your personal data is:

1.    your consent;

or

2.    that the processing is necessary for the performance of our contract with you

You have the right to receive your personal data from us in a commonly used and machine-readable format or instruct us to send this data to another organisation. This right does not apply where it would adversely affect the rights and freedoms of others. 

 

Rights related to automatic processing

This credit union uses an automated decision-making process for processing members’ loan applications to make sure that our decisions are quick, fair, efficient, and correct based on what we know.

The automated lending decision system looks at your credit score alongside information such as: 

  • the amount applied for
  • your income and expenditure
  • your history of repaying debts
  • the number and value of County Court Judgements (CCJs) 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
  • your age
  • and makes a decision based on either
    • Set policies e.g. the credit union does not lend to those less than 18 years of age
    • The predicted likelihood of the repayment of the loan based on the statistical analysis of whether individuals who had a similar credit profile repaid their debts in the past.

Members have the right to have the decision reviewed by a member of staff, express their point of view, and obtain an explanation of the decision and challenge it.

 

Right to withdraw consent

To the extent that the legal basis for our processing of your personal information is your consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

 

The right to complain to the Information Commissioner’s Office

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with the Information Commissioner’s Office which is responsible for data protection in the UK. You can contact them by:

Going to their website at: https://ico.org.uk
Phone on 0303 123 1113
Post to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF 

Contact us about your rights

For more information about how your rights apply to your membership of the Credit Union or to make a request under your rights you can contact the Operations Manager at info@credit-union.coop or 0207 561 1786. We will aim to respond to your request or query within one month or provide an explanation of the reason for our delay.

 

Contact details of the Credit Union

Name & Address: London Capital Credit Union, Jeremy Hopgood Rooms, Caxton House, 129 St John’s Way, London, N19 3RQ
Phone: 0207 561 1786
Email: info@credit-union.coop

 

Changes to this privacy policy

We can update this Privacy Policy at any time and ideally you should check it regularly here for updates. We won’t alert you for every small change, but if there are any important changes to the Policy or how we use your information we will let you know and where appropriate ask for your consent.

How We Decide to Whether to Offer a Loan – The Basics

The Credit Union’s primary objective is to help members avoid or escape from debt by promoting a culture of saving. When we offer loans, we only do so if the borrower agrees to save a little while they repay. The establishment of a savings habit is proven to reduce the harms and risks of long-term borrowing becoming problem debt. Basically, when we get a loan application our decision is based on the following two principles:

1. Do we trust the applicant to repay the loan?

2. Can the applicant afford the loan repayment

This guide is designed to help members understand our thinking so you can best prepare if you should need to apply or re-apply for a loan.

1. Key Points in Our Assessing Trust of the Applicant

a) Has the applicant started saving? The money we lend is members savings so, especially at busy times, we have to give priority to loan applications from members who have made at least one savings payment. That first payment is good evidence that you are a real person and helps us confirm identity.

b) Proper Proof of ID & Address? What forms of proof of identity and address has the member provided? If you are able to connect your bank account through ‘open banking as art of the loan application process it a good way of proving ID. First time loans may be required to use online Open Banking.

c) Previous Borrowing History. Has the applicant borrowed and repaid us previously? Previous good repayment record supports any application.

d) Did the applicant inform us of other money owed? Failure to list all debts in the application process is likely to result in the loan application not being approved. It suggests that the applicant is either not in control of their money or not being completely honest with us and in either case we cannot put our members savings at risk by lending. Credit Reference Agency checks are used to show us what money is owed and to whom.

e) Is the member sensible with money? When we review the bank transactions of the loan applicant, we often see patterns of expenditure that suggest the applicant is not taking a sensible approach to expenditure. Changes in the way they manage their finances would suggest that the loan would not really be necessary. We want to help people be in control their finances and do not want to lend members savings to people who are not deemed sensible with the way they spend. This may be things like gambling, excessive shopping and/or eating out/takeaway food deliveries.

f) Always be ‘up front’ in your application. Honesty pays. We do not judge.

2. Key Points in Our Assessing Affordability for the Applicant

a) Is this loan in the member’s best interest? The value of the loan application in comparison with your income is a key measure of affordability. The loan interest members pay on loans pays our staff salaries, but we are not out to profit from you, rather we want members to borrow less over time and take control of their finances.

b) Positive Bank Balance at Month End? Is there money left in the members bank account at the end of the month that would be sufficient to cover the loan repayment if approved? If not, the member must explain how the loan would become affordable, for instance, by reducing expenditure in other areas.

c) Is the applicant struggling with existing debts? When we review the bank transactions of the applicant we can see income and expenditure. If the loan applicant tells us how the loan will clear other debts and reduce their expenditure this will help us understand affordability.

d) Is the purpose of the loan considered sensible? If the applicant is not paying essential bills such as mortgage or rent then a loan for a car or holiday is likely to be unwise and unaffordable.

e) Has the applicant fully explained why they need to borrow? Always feel free to email or call us explaining the circumstances that mean you need to borrow. The reasons for needing to borrow are complex, but being honest and explaining the circumstances can often help the ordinary humans on the Loans Team at the Credit Union to be able to assess trust and affordability. You briefly explaining your thinking about affordability gives us confidence that you are thinking sensibly about money, and sometimes allows us to suggest alternatives that may well be in your best interest.

f) Is the loan to clear other more expensive debts? Credit Reference Agency checks are used to show us what money is owed and to whom. If your loan application is to pay off other debts, stop and list every one of those debtors.Work out the cost of each. Consider clearing one or two at a time if its your first Credit Union loan. Pick them off one or two at a time, the most expensive first.

g) Has the applicant stopped to think about affordability? The ‘Your Money’ section of our website provides access to a budget planner which, if used and shared, gives us good evidence of affordability. Particularly helpful for loan applicants in financial stress. We hope this gives you an idea of how we decide yes or no to loan applications. The decision is by one or more other credit union members on our Loans Panel. We hope this helps you understand our thinking so you can best prepare if you should need to apply or re-apply for a loan.

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