Right Way Credit Union Privacy Notice
Right Way Credit Union (“we”, “us”, “our” or “the credit union”) understands the business impact of personal data related risks and are committed to protecting and respecting your privacy.
Reference to “we”, “us” or “our” is a reference to Right Way Credit Union and for the purpose of the General Data Protection Regulation (GDPR) the data controller is Right Way Credit Union Credit Union registered address as given below.
The Policy sets out the lawful basis and specified purposes on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For website communication
By visiting our Site, you are accepting and consenting to the practices described in the Privacy Notice and full Policy for Data Security.
On an annual basis we will send requests to our members to ensure data held is kept updated.
Right Way Credit Union is registered in Scotland and has its registered office at 41 High Street Paisley PA1 2AH.
Right Way Credit Union is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Financial Services Register No. 446350.
The credit union does not consider its controlling of and processing of data to be on a large enough scale to employ a Data Protection Officer. All Directors, staff & volunteers are subject to continuous training in the importance of Data Protection. The credit union has a Data Protection representative who ensures this policy is reviewed no less than annually and will assist with queries raised by the membership, Directors, staff and volunteers.
Right Way Credit Union Privacy Notice
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
Right Way credit union may process, transfer and/or share personal information in the following ways:
For legal reasons
For performance of our contract with you
For our legitimate interests
With your consent
Sharing your personal information
We will disclose information outside the credit union:
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 the 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 for a period of time after you have left the credit union.
For a copy of our Policy for Data Retention please contact the office team on telephone number: 0141 889 7442.
Credit rating agencies
In order to process any credit applications you may make, we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as details 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 may exchange information about you with CRAs, including details 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 under data protection regulations are:
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, on request, a copy of your personal data.
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:
However, you may not erase this data where we need it to meet a legal obligation or where it’s 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:
We will only otherwise process it:
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:
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 may from time to time use 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:
and makes a decision based on either
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. A copy of our Policy for Lending can be obtained by contacting the office.
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:
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 us via email email@example.com or telephone 0141 889 7442. We will aim to respond to your request or query within one month or provide an explanation of the reason for our delay.
Our contact address details are:
41 High Street,Paisley, PA12 AH.
Changes to this Privacy Notice
We can update this Privacy Notice at any time and ideally you should check it regularly at www.rwcu.co.uk
We won’t alert you for every small change, but if there are any important changes to the Notice and or how we use your information we will let you know and where appropriate ask for your consent.
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