Privacy Notice

Our Privacy Promise

We promise,

• To keep your data safe and private
• Not to sell your data
• To give you ways to manage and review your marketing choices at any time.

Who We Are

No1 CopperPot Credit Union.

This section gives you the legal name of our company who holds your personal information – known as the ‘legal entity’ – and tells you how you can contact us.

No1 CopperPot Credit Union’s registered office is at Slater House, Oakfield Road, Cheadle Royal Business Park, Cheadle, Cheshire SK8 3GX and we are a company registered in England and Wales under company number IP000078. Our registered name is Number One Police Credit Union Limited, but we trade as No1 CopperPot Credit Union. We are registered on the Information Commissioner’s Office Register; registration number Z7902893, and function as the data controller when processing your data. We can be contacted at Slater House, Oakfield Road, Cheadle Royal Business Park, Cheadle, Cheshire SK8 3GX. Telephone 0161 741 3160, or email info@no1copperpot.com.

Information That We Collect

This explains what all the different types of personal information mean, that are covered by data protection law.

We use various kinds of personal information. They are grouped together in the below table. The groups are all listed here so that you can see what we may know about you. We do not use all this data in the same way. Some of it is useful for marketing, or for providing services to you. But some of it is private and sensitive and we treat it that way.

Where We Collect Personal Information From

This section lists all the places where we get data that counts as part of your personal information.

We may collect personal information about you from any of these sources:

Data you give to us:

This covers data given by you as well as data provided by people linked with your product or service, or people working on your behalf. This could mean a joint account holder, trustee, or a department of the Police Force.

• When you apply for our products and services
• When you talk to us on the phone or in person, including recorded calls and notes we make
• When you use our website, web chat, mobile device app or contact us through social media
• In emails and letters
• In financial reviews and interviews
• In customer surveys
• If you take part in our competitions or promotions.

Data we collect when you use our services:

This covers two things: details about how and where you access our services, and account activity that is shown on your statement.

• Payment and transaction data (we do not store card details. This includes the amount, frequency, type, location, origin and recipients. If you borrow money this would also include information on the loan including the amount borrowed, repayments amount and if it is paid in full and on time each month.)
• Profile and usage data. This includes the security details you create and use to connect to our services. It also includes your settings and marketing choices. We also gather data from the devices you use (such as computers and mobile phones) to connect to our internet and mobile service. We may also use cookies and similar tracking technologies to collect data from our website, mobile app and when you receive, open, or respond to emails we send you. You can find out more about this in our Cookies section.

Data from outside organisations:

• Credit reference agencies (e.g., Equifax, Transunion)
• Fraud prevention agencies
• Payroll service providers
• Public information sources such as the Financial Conduct Authority
• Government and law enforcement agencies
• Firms providing data services (we receive reports, such as open banking reports, that we use to better understand our customers and look for general patterns and trends)
• Other financial services companies (to fulfil a payment or other service as part of a contract with you, or to help prevent, detect, and prosecute unlawful acts and fraudulent behavior)
• Land agents (such as firms who do property valuations for mortgages)
• Social networks and other technology providers (for instance, when you click on one of our Facebook or Google ads)
• Employers (for instance, to get a reference if you apply for a mortgage)
• Public information sources such as the Electoral Register or Companies House
• Companies that introduce you to us, such as a broker
• Agents, suppliers, sub-contractors, and advisers
• Market researchers (who combine data from many sources to produce market trend reports and advice). These firms may contact you on our behalf to ask you for your opinions and feedback. Sometimes these firms will combine what you tell them with data from other sources to study it. They will use this to produce reports and advice that help us understand our customers’ point of view, so that we can improve the way we work as a business.

How We Use Your Personal Data and How the Law Protects You

Data Protection law states that we should only use your personal information when we have a lawful basis (proper reason) for doing so. This includes sharing it outside No1 CopperPot Credit Union. The law states we must have one or more of these reasons:

• To fulfil a contract we have with you, or
• When it is our legal duty, or
• When it is in our legitimate interest, or
• When you consent to it, or
• When it is in the public interest.

When we have a business or commercial reason of our own to use your information, this is called a ‘legitimate interest.’ We will tell you what that is, if we are going to rely on it as the reason for using your data. Even then, it must not unfairly go against your interests.

The law and other regulations treat some types of sensitive personal information as special category data. This includes information about racial or ethnic origin, sexual orientation, religious beliefs, trade union membership, health data, and criminal records. We will not request, collect or use these types of data without your consent unless the law allows us to do so. If we do, it will only be when it is necessary:

• For reasons of substantial public interest, or
• To establish, exercise or defend legal claims.

No1 CopperPot Credit Union takes your privacy very seriously and will never disclose, or share, your data without a legitimate reason for doing so. We only hold data for as long as is required according to the purpose for which the data was obtained and in line with our data retention policy. Where you have given consent for us to share information with you about our products and services, this can be withdrawn at any time. Only the personal data absolutely required for the purpose of each interaction will be requested, this could be account opening, servicing etc. Below you can see what we use your data for and why.

For processing special categories of personal information

Sharing and Disclosing Your Personal Information

All processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this Privacy Notice, the data protection laws and any other appropriate confidentiality and security measures.

We use a range of measures to keep your information safe and secure, which may include encryption and other forms of security. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards including obligations to protect any information and apply appropriate measures for the use and transfer of information.

We may share your personal information with outside organisations such as Credit Reference Agencies, data analytics companies or tax authorities. This is so that we can provide you with products and services, run our business, and obey rules that apply to us. Here we list the types of organisation that we may share your personal information with.

Authorities

This means official bodies that include:

• Central and local government
• HM Revenue & Customs, regulators, and other tax authorities
• UK Financial Services Compensation Scheme and other deposit guarantee schemes
• Law enforcement and fraud prevention agencies

Banking and Financial Services

Outside companies we work with to provide services to you and to run our business. These are types of firms that we use to help us run accounts, policies, and services.

• Agents who help us to collect what is owed to us.
• Credit reference agencies (such as TransUnion, Equifax, and Experian)
• Other financial services companies (to help prevent, detect, and prosecute unlawful acts and fraudulent behavior)
• Independent Financial Advisors or solicitors (if you have one). This could be someone who you, your employer, or product owner have selected to advise you on things like mortgages. We will not share any personal information unless they have your consent to ask us for it.
• Employers (for instance, to confirm your identity if we ask for a mortgage reference)
• Companies you ask us to share your data with, such as solicitors
• Suppliers, sub-contractors, and advisers.

Other services and schemes

These are organisations that we may need to share your personal information with, because of what you can do with the product or service you have with us.

• If you use direct debits, we will share your data with the Direct Debit scheme.
• If you have a secured loan or mortgage with us, we may share information with other lenders who also hold a charge on the property
• If we are contacted by a third party about fines, penalties or charges imposed on you, we may share this with your employer, or share your details with these third parties.

Outside companies we use to help grow and improve our business.

• Advisers who help us to come up with new ways of doing business. This might be a legal firm, IT supplier or consultancy.
• Organisations that introduce you to us or who we have a contractual agreement with. This might be a broker or a police federation.
• Technology providers that you use (such as websites you visit, social networks, and providers of apps and smart devices). If you allow it, these firms display messages to you and others about our products and services and use personal information to make sure these messages are relevant for you.
• Analytic companies who may correlate our data or help us to understand our membership base and the products type which would be most beneficial
• Organisations which provide marketing/communication services

Sharing data that does not say who you are

We may share some data with other companies, but only when no-one’s identity can be known or found out. One of the ways we can do this is by grouping members together. We may do this so we and those other companies can look for general patterns and trends in the data, while keeping the member identities secure.

We and those other companies do this to learn about the types of members we have, how they use our products, and how our products perform for them. The law says data is not considered to be personal information after customer identities have been securely hidden in this way.

Credit Reference Agencies (CRAs)

We may conduct credit and identity checks on you when you apply for a product or service and may use Credit Reference Agencies to help us with this. If you use our services, we may also use the CRA information to help us manage your accounts. This may include completing a credit check if you default on borrowing held with us. We will confirm that such agencies comply with the Data Protection Regulations in force at the time, be they inside or outside the EEA, and will ensure they are compliant with the Credit Reference Agency Information Notice (CRAIN).

We will share your personal information with CRAs, and they will give us information about you. The data we exchange can include:

• Name, address, and date of birth
• Credit application
• Details of any shared credit
• Financial situation and history
• Public information, from sources such as the electoral register and Companies House
• Fraud prevention information

We will use this data to:

• Help us to assess whether you can afford to make repayments
• Make sure what you have told us is true and correct
• Help detect and prevent financial crime
• Manage accounts with us
• Trace and recover debts
• Make sure that we tell you about relevant offers.

We will go on sharing your personal information with CRAs for as long as you are a member. This will include details about your settled accounts and any debts not fully repaid or not repaid on time. It will also include details of funds going into the account and the account balance. If you borrow from us, it will also include details of your repayments and whether you repay in full and on time. The CRAs may provide this information to other organisations who wish to check your financial status. We will also tell the CRAs when you settle your accounts with us.

When we ask CRAs about you they will note it on your credit file. This is called a credit search. Other lenders may see this, and we may see credit searches from other lenders.

If you apply for a product with someone else, we will link your records with theirs. We will do the same if you tell us, you have a spouse, partner, or civil partner. You should tell them about this before you apply for a product or service. It is important that they know your records will be linked together, and that credit searches may be made on them.

CRAs will also link your records together. These links will stay on your files unless one of you asks the CRAs to break the link. You will normally need to give proof that you no longer have a financial link with each other. You can find out more about the CRAs on their websites, in the Credit Reference Agency Information Notice. This includes details about:

• Who they are
• Their role as fraud prevention agencies
• The data they hold and how they use it
• How they share personal information
• How long they can keep data
• Your data protection rights

Here are links to the information notice for each of the three main Credit Reference Agencies:

• TransUnion
• Equifax
• Experian 

Automated Assessment

We sometimes use systems to make automated decisions about you. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. We may also use automated decision making in processing your personal and financial information to make credit decisions. 

Account Opening

The Credit Union uses a company called NestEgg Ltd to process this data on our behalf. NestEgg Ltd provides an automated ‘decision’ to help the Credit Union make it easy for members to apply for loans and savings accounts. NestEgg Ltd is not responsible for making decisions, they do not see your personal information. Their software makes a recommendation to a loans officer.

When you apply for a loan and/or savings account up to five searches may appear on your credit file. For the purposes of credit scoring, this will typically only affect your credit score as if one credit application were made. Each of these five ‘footprints’ relate to the different sources of data being used to assess an application; these include the credit report itself and an affordability check. The Credit Union needs to prove the information belongs to you which is when an ID check is required. In cases where an application is made by a new member; the Credit Union will use an ID check and may also run a report to check ownership of any bank account details you may give us. These checks are required by law to prevent money laundering. Some of these footprints will be in the name of NestEgg Ltd and others in the name of the Credit Union.

Your rights

You can object to an automated decision we have made and ask that a person reviews it.

Audit Purposes and Regulators

We may share your data with external auditors, this is a legal requirement and is the basis we would process your information in this case. Your data may also be shared with internal auditors and regulators. The Prudential Regulation Authority (PRA) require us to have an internal audit function (whether internal or external to the Credit Union). The regulators can also request information which we must provide. This is therefore done on a legal basis to ensure we meet our regulatory requirements.

Recording Phone Calls

We may monitor or record phone calls with you 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 detect or prevent fraud or other crimes. Conversations may be recorded for staff training purposes.

Fraud Prevention Agencies (FPAs)

We may need to confirm your identity before we provide products or services to you. Once you have become a member, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies to help us with this. The organisations we share data with are:

• Registered Fraud Prevention Agencies (FPAs)
• Other agencies and bodies acting for the same purpose
• Industry databases used for this purpose

Both ourselves and fraud prevention agencies can only use your personal information if we have a valid reason to do so. It must be needed for us to obey the law or for a ‘legitimate interest.’ A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for you. We will use the information to:

• Confirm identities
• Help prevent fraud and money-laundering
• Fulfil any contracts you have with us.

We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent, and prosecute crime.

Other organisations can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.

These are some of the types of personal information that we use:

• Name
• Date of birth
• Residential address
• History of where you have lived
• Contact details, such as email addresses and phone numbers
• Financial data
• Data relating to your products or services
• Employment details
• Whether you have been a victim of fraud
• Data that identifies computers or other devices you use to connect to the internet. This includes your Internet Protocol (IP) address.

Automated decision making on fraud prevention is covered under the automated decision making section.

Detecting fraud

We use your personal information to help decide if your accounts may be being used for fraud or money-laundering. We and other organisations acting to prevent fraud may process your personal information in systems that look for fraud by studying patterns in the data. We may find that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. Either of these could indicate a possible risk of fraud or money-laundering.

If we or an FPA decide there is a risk of fraud, we may stop activity on the accounts or block access to them. FPAs will also keep a record of the risk that you may pose. This may result in other organisations refusing to provide you with products or services, or to employ you.

Web Chat Providers

As we use a chatbot, the providers have access to limited information. The information which they can view and hold is your IP address and a generalised area from which you are making contact. Chat conversations are not stored against an IP address and cannot be used to track or identify a user.
They will automatically expire data on visitors 30 days after a chat conversation to ensure they comply with data protection retention requirements. They have a dedicated Data Protection Officer to oversee and advise on their data management.

Your Rights

This section explains your data privacy rights and how to contact us about them.
You have several rights around use of your personal information. If we receive a request from you to exercise any of the below rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
If you wish to exercise any of your rights you can call us on 0161 741 3160 or email us at info@no1copperpot.com.

The right to be informed

You have the right to be informed about the collection and use of your personal information. This means that we should provide you with details of how we use your personal information. This Privacy Notice is an example of this.

The right of access

You have the right to access a copy of your personal information, referred to as a Subject Access Request (SAR).

The right to rectification

You have the right to question any information we have about you that you think is incorrect. We’ll take reasonable steps to check this for you and correct it.

The right to erasure

You have the right to have your personal information deleted or removed if there is no reason for us to keep it. This is also known as ‘the right to be forgotten’. There may be legal or other official reasons why we need to keep or use your personal information.

The right to restrict processing

You have the right to restrict processing of your personal information. This means it can only be used for certain things, such as legal claims or to exercise legal rights. You can ask us to do so if your personal information is not accurate, has been used unlawfully, is not relevant anymore, or if you have already asked us to stop using your personal information but you are waiting for us to tell you if we are allowed to keep on using it. If we do restrict your personal information in this way, we won’t use or share it in other ways while it is restricted.

The right to data portability

You have the right to get certain personal information from us as a digital file. This means you can keep and use it yourself, and give it to other organisations if you choose to. If you want, we will give it to you in an electronic format that can be easily re-used, or you can ask us to pass it on to other organisations for you.

The right to object

You have the right to object to us keeping or using your personal information. There may be legal or other official reasons why we need to keep or use your personal information.

Rights in relation to automated decision making and profiling

You have rights around automated decision making and profiling. Automated decision making means a decision made solely by automated means, without any human involvement. Profiling means the automated processing of your personal information to evaluate certain things about you. You have the right to information about these kinds of processing, and the right to ask for human intervention or to challenge an automated decision.

The right to withdraw consent

You have the right to withdraw your consent for us to use your personal information at any time. This will only affect the way we use personal information when our reason for doing so is that we have your consent.
If you withdraw your consent, we may not be able to provide certain products or services to you.

Safeguarding Measures

No1 CopperPot Credit Union takes your privacy seriously and takes every reasonable measure and precaution to protect and secure your personal data. We work hard to protect you and your information from unauthorised access, alteration, disclosure, or destruction and have several layers of
No1 CopperPot Credit Union, Privacy Notice, Version 9.3, updated 09/01/24
security measures in place, including: – SSL, TLS, encryptions, restricted access, IT authentication, firewalls, anti-virus/malware. Sensitive Data, in relation to you, has no special forms of encryption. It is protected in the same way as all other data as described above.

Transfers Outside The EU

We will only send your data outside of the UK and European Economic Area (‘EEA’) to:

• Follow your instructions, for example issuing a statement
• Comply with a legal duty, for example, we may be required to share information about US citizens with the US tax authority.
• Work with our suppliers who help us run your accounts and services

If we do transfer your personal information outside the UK and EEA to our suppliers, we will make sure that it is protected to the same extent as in the UK and EEA. We’ll use the below safeguard:

• Put in place a data sharing agreement or contract with the recipient that means they must protect it to the same standards as the UK and EEA.

Consequences of Not Providing Your Data

We may need to collect personal information by law, or under the terms of a contract we have with you or are entering with you. If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts or policies. It could mean that we cancel a product or service you have with us.

Any data collection that is optional would be made clear at the point of collection.

Marketing

We may use your personal information to make decisions about what products, services and offers we think you may be interested in. This is what we mean when we talk about ‘marketing’. We can only use your personal information to send you marketing communications if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not conflict unfairly with your own interests.

The personal information we have for you is made up of what you tell us, data we collect when you use our services, and we may use data from external sources such as CRA’s. We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. This is called profiling for marketing purposes. You can contact us at any time and ask us to stop using your personal information this way.

If you allow it, we may show or send you marketing material online, on our own and other websites including social media, mobile applications, email, post, or by text message. Some of these are shown to you because they are based on explicit consent you have given us when joining the Credit Union, e.g., marketing through post, text, or email. Consent on these can be revoked at any time by contacting the Credit Union. Other elements of marketing communications such as social media, our website and external website advertising could be based on cookies which you will have accepted.

No matter what your marketing preferences are, you will still receive important information such as updates on or changes to your existing products and services.

We do not sell the personal information we have about you to outside organisations. We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business. If you change your mind, you can contact us to update your choices at any time.

Cookies

We may use cookies and similar tracking technologies on our websites and in emails we send to you. Cookies are small computer files that get sent down to your PC, tablet, or mobile phone by websites when you visit them. They stay on your device and get sent back to the website they came from when you go there again. Cookies store information about your visits to that website, such as your choices and other details. Some of this data does not contain personal details about you, but it is still protected by this Privacy Notice.

To find out more information about how we use cookies please see our cookie privacy notice by clicking here.

Email Tracking 

We track emails to help us improve the communications we send. We use small images called pixels within our emails to tell us things like whether you opened the email and how many times. We may also set a cookie to find out if you clicked on any links in the email.

How Long We Keep Your Data

No1 CopperPot Credit Union only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We will keep your personal information for as long as you are a member of the Credit Union.

Your data will be destroyed 6 years after your membership has ceased however, we may keep your data for up to 10 years for one of these reasons:

• To respond to any questions or complaints
• To show that you were provided with a positive outcome 
• To study customer data as part of our own internal research
• To obey rules that apply to us about keeping records. For example, the Money Laundering Regulations require us to retain certain data for a minimum of 5 and a maximum of 10 years
• We may also keep your data for longer than 10 years if we cannot delete it for legal, regulatory, or technical reasons. If we do, we will make sure that your privacy is protected and only use it for those purposes. An example of this is that we must retain your name, address, email address, transactional information, joining and leaving date, to meet our obligations under Section 30 of the Co-operative and Community Benefit Societies Act (member register). Date of birth is also retained as this allows us to differentiate between members who share the same name and live at the same address.

Information relating to a defaulted account will be retained indefinitely. The reason for this is you will still be classed as a member of the Credit Union, and we may use this information to make future decisions on any accounts you may wish to change or open.  

We will only use your personal information for these purposes and will make sure that your privacy is protected.

How to Get A Copy of Your Personal Information

You can access the personal information we hold for you by calling us on 0161 741 3160, emailing us at info@no1copperpot.com or by writing to us at this address:

Subject Access Request

No1 CopperPot Credit UnionSlater House,

Oakfield Road,

Cheadle Royal Business Park,

Cheadle, Cheshire

SK8 3GX

How to Make a Complaint

Please let us know if you are unhappy with how we have used your personal information. You can contact us by email info@no1copperpot.com, or by telephone 0161 741 3160, or by letter to Slater House, Oakfield Road, Cheadle Royal Business Park, Cheadle, Cheshire SK8 3GX.

You also have the right to complain to the Information Commissioner’s Office (ICO). You can find out how to complain on their website at https://ico.org.uk/, you can do this online on their website, or by contacting them on 0303 123 1113.

No1 CopperPot Credit Union, Privacy Notice, Version 9.3, updated 9th January 2024.