Lucan District Credit Union as a data controller
Lucan District Credit Union LDCU is a member-owned financial organisation that provides financial services to its members. We are committed to protecting the privacy of personal data under our control and this statement summarises our approach. While providing personal data to us in the course of business with LDCU or using our website, we will manage your data in accordance with European and national law.
This is a summary document to provide a clear indication of our processing activities and to inform you of your rights. For more information, please contact our Data Protection Representative on 01 6281642, or e-mail email@example.com
Storage of personal data -
Purpose of processing
Criteria for the storage of personal data
From closing of the account, or greater where regulation mandates.
Loan related data (transaction details)
From closing of the loan
Loan protection insurance
From closure of a loan account
Life & Pension products
From the provision of advice or the termination of a life or pension product
Direct marketing data
From the last communication
From recording. Up to 6 years in the event of an incident where a material risk of a liability exists
Incidents or complaint reports
Small balance write-offs / Un-cashed Cheque details
Documentation relating to revenue
Stored as mandated by law plus 12 months
AML and Fraud prevention documentation
Stored as mandated by law plus 12 months
Records and explanation of transactions, and of the provision of service
As mandated by the CU Handbook published by the Central Bank.
Nothing in this section creates an obligation upon the Credit Unions to retain personal data on behalf of a subject.
1.THE PERSONAL DATA THAT WE PROCESS AND WHY
Purpose: We obtain personal data from you to manage your relationship with LDCU, administer your savings and fulfil our legal obligations. This may include identification, taxation, beneficial ownership, bank details, nominee details and security data, and for the purpose of AML legislation further details about your identity and source of income.
Legal basis for processing; we may rely upon our agreement with you, the legitimate interest of LDCU to provide financial services in accordance with the Credit Union Acts and Central Bank guidelines and to administer the organisation in an efficient manner, our obligations under law, the vital interest of the member or consent as a basis for processing your membership data.
Purpose: We obtain personal data from you to assess, approve or manage a loan to you or to which you are a party, for the recovery or transfer of debt, the administration of related insurance and to fulfil our legal obligations. This may include identification, taxation, proof of income and outgoings, credit records, bank details, and details relating to third parties such as spouse, dependants or guarantors.
Legal basis for processing; we may rely upon our loan and membership agreements with you, the legitimate interest of LDCU to provide credit services and to recover debt in an efficient manner, our obligations under law, or consent as a basis for processing your personal data in relation to a loan
Life & Pensions
Purpose: We obtain personal data from you to provide advice on or effect the purchase of life and pensions products. This may include identification (list categories of data here)
Legal basis for processing; we may rely upon our contractual arrangements with you, the legitimate interest of LDCU to provide life and pension services, our obligations under law, or consent as a basis for processing your personal data.
Purpose: We obtain personal data from you to promote LDCU services and activities, this may include your name and contact details. Examples of activities include competitions, quizzes and surveys.
Legal basis for processing; we may rely upon the legitimate interest of LDCU to promote services or consent as a basis for processing your personal data. Note: you can decide to opt-out of direct marketing communication at any time.
CCTV and voice recording
Purpose: CCTV recordings are for the purpose of safety, security, or transaction monitoring.
Legal basis for processing; we may rely upon the legitimate interest of LDCU protects its interests and protect it from liabilities as a basis for processing such recordings.
2. TRANSFERRING YOUR DATA TO A THIRD PARTY
There are many activities of the credit union that require your data to be transferred to a third party. They may include the following categories of recipients; Revenue, a state regulator or individuals appointed to maintain regulatory compliance, auditors, advisors, Life & pensions companies, the Credit Union Development Association (CUDA), CUSOP (Payments) DAC, CUNA Mutual, Central Credit Register, The Irish Credit Bureau, Insurance providers, professional advisors, the collection or transfer of debt, the board of the Credit Union, IT and support providers, and electronic payment organisations.
In any event, personal data shall only be transferred for specific purposes that are in the legitimate interest of the Credit Union, are subject to a contract with you, are in your vital interest, or are required by law. We may also transfer personal data with your consent.
4. WHERE YOU HAVE PROVIDED CONSENT
Where we are processing data based on your consent you may withdraw that consent at any time.
5. INTERNATIONAL TRANSFER
The Credit Union does not currently transfer personal data to any recipients outside of the EEA European Economic Area unless such transfer is of a member’s data to the member and upon that member’s request, or in the course of debt recovery. Where you seek advice or purchase a life & pensions produce, the company providing that product may transfer your data to a location outside of the EEA. Where you purchase a product, that company will always inform you of any international transfer arrangements prior to entering into an agreement with them.
6. INFORMATION RELATING TO CHILDREN AND VULNERABLE PERSONS
The processing of personal data relating to minors receives special attention under Data Protection Regulation and we shall treat this information with particular care. Children are defined as under 16’s in Ireland. Information obtained about children shall comply with the requirement for parental consent and shall receive additional consideration while planning an operational process.
7. SPECIAL (SENSITIVE) DATA
The Credit Union recognises special categories of data, specifically personal data revealing racial or ethnic origin, political opinion, religious or philosophical beliefs, trade union membership, genetic or biometric data, or a subject’s health or sexual life. The processing of these categories of information shall typically require consent. Health details may be required for the purpose of insurance or the approval of a loan.
8. YOUR RIGHTS
In addition to the right to know the information on this data protection statement, subjects also have the right to:
- Information on whether we have Personal Data relating to a subject, the categories of data and the purpose of processing.
- Access your personal data. Where the format is not reasonably understood, this shall be delivered in an intelligible format.
- Have inaccurate, incomplete, or out-of-date personal data that we hold about you corrected or deleted.
- Withdraw consent for your personal data to be processes - where it was obtained from you on the basis of consent.
- Be informed if a failure to provide the personal data will have any direct and material personal consequences.
- Make a submission on any automated decisions making processes or profiling of you.
- Transfer your data to another controller.
- Have your personal data excluded from certain categories of processing.
- Lodge a complaint with the Data Protection Commissioner. Contact details for the DPC can be found at www.dataprotection.ie.
- There are some limitations to these rights.
- You can contact us to exercise these rights in branch or by e-mail at firstname.lastname@example.org or on 01 6281642
- The Credit Union will require proof of your identity prior to discussing or providing access to your personal data
9. DATA RETENTION
We retain personal data that you submit to us only for as long as is necessary for the purposes for which it was obtained, or as required by law. The Credit Union reserves the right to delete personal data prior to the conclusion of the retention period.
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