Privacy Policy

• Credit reference agencies.
• Government bodies and agencies.
• HM Revenue & Customs and other tax authorities.
• Regulators.
• Law enforcement agencies.
• Fraud prevention agencies.
• Insurers.
• The Electoral Roll and other sources of publicly available information (for example Sanctions list, media).
• Our service providers.
• Companies and organisations that introduce you to us.
• Financial advisers.
• Land agents.
• Card associations.
• Retailers.
• Comparison websites.
• Market research providers.

Tracing and debt recovery agents.

In the event that you are providing information about another individual, we will assume that you have told them that you are sharing their details and where they can find more information on how we may process their details.

• We use the information to carry out our obligations to you, as part of an agreement between you and London Mutual Credit Union.
• We must use the information to comply with the law or in the public interest.
• We use the information to carry out our legitimate business interests.
• You have given us consent to use the information.
• We use your information to protect your vital interests (for example in very exceptional circumstances when we believe it is in your best interests).

You will find out more about how we use your information in the sections below.

We use your information to check that it is you when you open an account. To do this, we collect and share your information with databases held by credit reference and fraud prevention agencies. This is so that we can verify your identity.

It’s all about keeping your money and personal details safe. We check your identity to:

• Make it harder for criminals to use false names and addresses, steal the identities of innocent people and access financial products and systems by pretending to be you.
• Help prevent fraud and stop money laundering.
• Uphold our legal obligations and complete necessary due diligence checks to make sure we know our customers.

We may also check your identity for our legitimate business interests. For example, to follow guidance and best practice set by our regulators. However, we will always make sure that the way we process your information is not unfair to you.

• Process your application for a product or service with us.
• Provide services based on your relationship with us for example issuing cards, administering payments on a current account or paying interest on a savings product.
• Manage your membership with London Mutual Credit Union and keep in touch with you.
• Send you communications to service your accounts, products and services.
• Manage any queries and complaints you might have.
• Make sure the data we hold about you is correct and up-to-date.

In managing your accounts and relationship with us, we may use information we already hold about you (for example your address and contact details). This is so we provide you with the best experience and ensure that we hold consistent and correct information about you across our systems.

We will process your information in this way when it is required as part of the terms and conditions agreed between us, and also when you ask us to carry out activities that need your authorisation (for example when you ask us to make a payment).

We may also need to use profiling (where we use your information to categorise groups of members and customers together based on their behaviours and interactions). This helps us make sure that we are being fair and consistent in the way we treat our members.

We may need to use your information when it is necessary for our legitimate business interests. This will mainly be so that we can uphold our commitment as a responsible lender and follow guidance from our regulators. We will always ensure the way we process your information is safe and not unfair to you.

We do this to:

• Assess your creditworthiness, once you are over 18, and consider whether we believe you can afford to take out a product or service.
• Check the information you have provided to us is accurate.
• Prevent criminal activity and financial crime including fraud and money laundering.
• Manage your ongoing relationship with us (for example managing your overdraft limit, once you are over 18).
• Trace and recover debts.
• Make sure any offers we propose are appropriate (when we have the right to do so).

Four things you need to know about credit referencing:

1. When we ask a credit reference agency to do a search on our behalf, this may leave a search footprint on your credit file that may be seen by other lenders. This happens whether or not you, or London Mutual Credit Union, choose to proceed with the application.
2. The number of searches carried out may have an impact on credit decisions made by us and other lenders.
3. If you are making a joint application, your credit records will be linked together. This creates what is known as a ‘financial association’ at credit reference agencies. So, you should always discuss and agree this with other applicants before disclosing their information to check that they are happy to proceed.
4. Information about any financial associations will be shared with other lenders if either of you make a credit application in the future – whether it is in just your name or together with someone else. London Mutual Credit Union may receive and use information about your existing financial associations as part of our decision-making process.

Why do we share your information with credit reference agencies?
We will share your information with a credit reference agency when it is necessary in line with the terms and conditions agreed between us. This could be when you are applying for a product or as part of our ongoing relationship with you.

We also collect and use your information to help us improve our credit risk systems and policies to make sure we meet the needs of our members.

As a responsible lender, it is in our legitimate business interests to make sure the products we provide you are affordable and suitable for your circumstances. So, we share your information with credit reference agencies to check that we have sufficient data to make well-informed decisions about offering credit – decisions that don’t put you at risk. It also

How do we use your information in this way?
We share your personal information with fraud prevention agencies to help prevent financial crime. If required for fraud or criminal investigation reasons, we (and the fraud prevention agencies) may also allow law enforcement agencies to access and use your information.

What information do we share?
The personal information we might need to share in this way includes:

• Your name
• Your address
• Your date of birth
• Your financial information
• Your employment details
• Identifying information (such as your IP address).

We will share your information in this way when it is necessary as part of the terms and conditions agreed between us, either when you are applying for a product or as part of our ongoing relationship.

Why do we share your information in this way?
We have a legitimate business interest to check people’s identity, and identify and prevent financial crime including fraud and money laundering. Sharing your information in this way, when necessary, allows us to protect your financial security as well as that of our other members and customers. It also makes sure that we are complying with the law.

A little bit about automated decisions
Sometimes when processing people’s personal information, we might use technology that makes automated decisions about our members. This means that we may automatically decide that someone poses a financial crime risk if:

• The information processed reveals behaviour that indicates financial crime.
• The information provided is different to information previously given.
• Someone appears to have deliberately hidden their true identity.

What happens if a financial crime risk is detected?
We take financial crime seriously. And if we, or a fraud prevention agency, believe that someone poses a financial crime risk then we may refuse to provide the services that they have asked for. We can also stop providing services they already have with us.

If they apply for a job with us, and financial crime is detected, we may not employ them. Or, if they work for us already, we may stop their employment.

A record of any fraud risk will be kept by the fraud prevention agencies and this could mean that other providers refuse to offer services, finances or employment. Fraud prevention agencies can hold onto someone’s personal data for different periods of time, depending on the situation. If someone is considered a fraud risk, their data can be held for up to six years.

How do we use your information in this way?
We will share necessary information with our partners when:

• You hold, or are applying for, a product underwritten and managed by one of our partners.
• We need to let them know that you’re a London Mutual Credit Union member and you need to receive the product (subject to eligibility).
• Discussing any claims, queries or complaints that may arise.
• To help them provide products and services to us.
• We need to update them about a change to your address or contact details.

Our partners will also collect and use your information to manage the products and services that you have with them. As this then makes them the ‘data controller’, they will provide more details on how they process your information at the time when it is collected by them or shared by London Mutual Credit Union.

When selecting our partners, we take appropriate steps to make sure that they have adequate protection in place and that they follow data protection legislation.

Why do we need to use your information for this?
We will use your personal information to meet the promises we have made in the terms and conditions of your product or service. We also use your information to understand your needs so that we can accurately advise on the products and services that are right for you.

We may also use it for our legitimate business interests. For example, when we need to make sure that the terms you have agreed to will be upheld, or to follow best practice from regulators.

We will always keep your best interests at heart and make sure that the way we process your information is not unfair to you.

We may also need to ask for ‘special category data’ (such as information about your health) from time to time, to check whether certain products and services are suitable.

• Assess the likelihood that your circumstances have changed.
• Work with you through challenging times, by understanding and supporting your needs.
• Recover any outstanding money owed to us (this could include trying to locate you).
• Help us decide on any further action we may need to take in order to recover money owed (for example whether we need to consider legal action or using a debt recovery agent).

How we use your information in this way?
We will process your information in this way when it is necessary to meet the promises we have made in the terms and conditions of your product or service, and also when you ask us to carry out activities that need your authorisation (for example when you have requested for someone to act on your behalf or if you choose to give us information about your health or any criminal convictions).

When necessary, we will share your information with individuals and organisations that you have asked to act on your behalf (for example Citizens Advice and Step Change) as well as credit reference agencies, solicitors, tracing and debt collection agents, home visit agents and debt purchasers.

To carry out these activities, we may need to use profiling (where we use your information to categorise groups of members and customers together based on their behaviours and interactions). This helps us make sure that we are being fair and consistent in the way we treat our members and customers and also to support those who may be experiencing financial difficulty.

We may also use your information for our legitimate business interests. Rest assured, we will always ensure that the way we process your information is safe and not unfair to you.

Information about defaults
We will always look to work with you if you get into financial difficulty, so please do get in touch with us first if you are struggling to make repayments.

We will follow our credit control procedure and if we fail to reach an agreement to repay the debt, we will record a default with credit reference agencies and this will remain on their records for up to 6 years.

We also collect and use your information to help us plan and tailor the delivery of our marketing campaigns.

Your marketing preferences, your choice
When it comes to receiving marketing, you are in control. And you are free to choose if you want to hear from us. You can also change your mind at any time. As a member you can update your marketing preferences at any time:

• Through your Online banking
• By sending us an email at [email protected]
• In your local branch
• By writing to us at London Mutual Credit Union, 4 Heaton Road, Peckham, London, SE15 3TH

We’ll never pass on your details to anyone else for their marketing purposes either.

These include using your personal information to carry out a range of activities that ensure we comply with the requirements set out by our regulators (for example Financial Conduct Authority – FCA and Prudential Regulation Authority – PRA) and in relevant legislation (for example Data Protection Legislation and Anti-Money Laundering Regulations). We also disclose information to HMRC and other government bodies when we are required or permitted to do so.

How do we use your information in this way?
Sometimes, we are required by law to produce reports or statistical modelling that we disclose to regulators or government bodies (for example when we need to report our complaints statistics to the FCA). To produce these reports, we may need to use profiling (where we categorise your behaviours, interactions and/or characteristics alongside other members). This helps us make sure that our reporting is accurate.

In certain circumstances, we will process your personal information in this way for our legitimate business interests. This is when we have legal obligations to process your information but flexibility in how we do this. For example: when data protection legislations govern that we need security controls in place to make sure your information is not disclosed to the wrong person. To comply with this obligation, we have stringent identification and verification processes in place when you open a product, together with numerous security controls (for example our authentication process to identify you when you use our products and services).

We collect and use your personal information to help us make our business better, improve products and services and enhance how we engage with members and customers. This includes:

• Enhancing your experience in branch, online and on the phone, so we can provide the best possible service now and in the future.
• Understanding your needs and looking at how you engage with London Mutual Credit Union.
• Creating and improving the products and services we offer.
• Develop and improve our processes and policies so we can meet the needs of our members.
• Understanding our members’ diverse backgrounds to help inform our strategy.
• Planning and tailoring how we communicate and provide relevant content to you.
• Developing our business and understanding how we are performing as a credit union.

How do we use your information for this?
We look at you and how you engage with us (for example how long you have been a member or whether you open our emails), your transactions and how you use our products and services (for example the types of accounts you have and how you use our Online banking and Mobile app). Sometimes, we will collect information about you from organisations carrying out market research on our behalf to make sure you had a positive experience in our branch network or call centre, or to ask your opinion on our products and services, or trends in our industry.

Then, we structure and analyse this information to consider how you might use our products and services in the future. We may also use your information to categorise groups of members who interact and engage with us in similar ways.

We will also use information we have collected from credit reference agencies and other organisations to profile your information (for example where we categorise behaviours, interactions and/or characteristics, both now and in the future). We will do this whether or not you, or London Mutual Credit Union, choose to proceed with the application. This is part of what we call ‘statistical modelling’, helping us to review our risk appetite when making lending decisions.

Why do we use your information in this way?
We might use your information in this way when it is in our legitimate business interests. Your information and views help us understand the ever-changing needs of our members, putting you at the heart of decisions we make about our products and services. By doing this, we can keep evolving what we offer and growing as a society.

Profiling your information alongside other members and customers also helps us to ensure that we are providing a consistent service and giving people the best products and advice at the right times. We will always make sure the way we process your information is safe and not unfair to you. Where possible, we will keep your details anonymous and use your information only to produce statistical reports.

How do we use your information in this way?
We have stringent processes in place to keep your personal information safe and we won’t use it in a way that is unfair to you. When we use your information for testing, we:

• Always do this in a secure and controlled environment.
• Only use the minimum amount of data necessary for the testing.
• Only use carefully selected specialist service providers, where necessary.
• Only hold your information in this way for as long as needed to carry out testing.

Why do we use your information in this way?
Using your information for testing is necessary for our legitimate business interests as it allows us to maintain and improve the security, integrity and performance of our systems. Also, being able to develop systems with members in mind enhances the experiences you have with London Mutual Credit Union.

We’ll aim to keep your personal information for:

• As long as you are a member of London Mutual Credit Union.
• Up to 12 years after your account, product or service has closed or ceased.

We may keep your information for longer than indicated if we cannot delete it for legal, regulatory, or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.

Keeping your information safe
We are committed to taking good care of your personal information safe and we have stringent security measures in place to keep it well-protected.

You can ask us to correct your information by writing to us at [email protected] or London Mutual Credit Union, 4 Heaton Road, Peckham, London, SE15 3TH. We will review your request and get back to you within one month. If we have shared your information with other organisations, then we will do our best to let them know that you have asked for the information to be rectified.

To do this, you can write to us at [email protected] or London Mutual Credit Union, 4 Heaton Road, Peckham, London, SE15 3TH. We will review your request and get back to you within one month.

Just so you know: there are some things that we need to use your information for. For example, to take care of your accounts, products or services, to help protect you from fraud and to fulfill legal and contractual obligations. If processing is restricted, we will continue to store your information and process it as required by law.

If we have shared your information with other organisations, then we will do our best to let them know that you have asked for the information to be restricted.

You can object to us processing your information by writing to us at [email protected] or London Mutual Credit Union, 4 Heaton Road, Peckham, London, SE15 3TH. We will review your request and get back to you within one month.

Just so you know: there are some situations where we won’t stop processing your information despite your objection. We will review your request and let you know our reasons for agreeing or not agreeing.

You can ask us to erase your information by writing to London Mutual Credit Union, 4 Heaton Road, Peckham, London, SE15 3TH. We’ll get back to you within one month.

If we have shared your information with other organisations, then we will do our best to let them know that you’ve asked for the information to be erased.

You can do this by writing to us at [email protected] or London Mutual Credit Union, 4 Heaton Road, Peckham, London, SE15 3TH. We will review your request and get back to you within one month.

If you still have unresolved concerns, you also have the right to complain to data protection authorities. The authority overseeing data protection in the UK is the Information Commissioner’s Office. Their contact details are below:

Information Commissioner Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 0303 123 1113

If you’re a member and you have consented to marketing, you can change your marketing preferences at any time by sending us an email, by post or by popping into branch.

If you change your name, address, phone number or email address, please let us know straight away. You can update your contact details at any time in the Online Banking. Alternatively, you can pop in to your local branch.

When do we use automated decision making?

1. To assess your application and check if we can approve you for credit, to make sure that we are lending responsibly.
2. To assess if we can offer you a financial product and work out the level of interest that you will pay. This helps us make sure that we are fair and consistent in our product offerings.
3. To check if someone is making a fraudulent application or if there is activity on your account that needs further review. This is so we can protect your money and protect you from financial crime.
4. To decide if you are, or continue to be, eligible for the product or service you have chosen.

What information do we use to make these decisions?
For automated decision making, we use information that we have collected or hold about you from your applications. Sometimes, we might also use information from other sources such as credit reference or fraud prevention agencies but we check this against the information you give us.

Profiling
Profiling is used to make automated decisions. This is where we combine your information with information about others so that we can:

• Understand trends in traits and behaviours.
• Make predictions about how you might use our products and services in the future.
• Analyse data to improve our service and generate alerts (for example where we suspect that you may be the victim of financial crime).

Why we use your information in this way?
We use automated decision making to check that we can enter into an agreement with you, and also carry out our legal and regulatory obligations. Sometimes, it is required by law (for example when complying with UK money laundering regulations).

In certain circumstances, you have the right to ask for a decision to be reviewed by a person.

• Have a Power of Attorney or a third party mandate to act on a member’s behalf.
• Are the Personal Representative registering the death of a member.
• Are acting as the guarantor on a member’s loan.
• Are a beneficiary of an account held in trust.
• Are a parent or guardian accompanying a child opening an account in their own name.
• Are supporting a member when English isn’t their first language.
• Are raising a complaint but aren’t a member of London Mutual Credit Union.
• Are acting on behalf of our member, either in a professional capacity (for example a broker) or a personal capacity (for example a family member).
• Are a child with an account opened on their behalf by an adult.

How do we collect or use this information?
In most cases, we will collect this information from the individuals directly. But there might be times when our members or customers provide their details. If you are providing information about another individual, we will assume that you have told them that you are sharing their details and where they can find more information on how we may process their details.

Why do we need this information?
We might need to use this information to confirm their identity, help manage others’ accounts, prevent fraud and engage with members and customers.

We will only use this information if we have a legal reason or legitimate business interests to do so.

• You request for us to do so.
• We are required or permitted to by law.
• We are sharing data with a third party to support us in managing your account and running London Mutual Credit Union.

When working with our suppliers and/or transferring information to countries outside the UK, we take appropriate steps to ensure that there is adequate protection in place and that data protection legislation is followed.

This could be by:

• Ensuring that we transfer information to countries that we believe have comparable data protection legislation to the UK.

Putting suitable clauses in our contracts so that organisations take appropriate steps to comply with UK data protection law.

How do we use your personal information in this way?
When we collect your information using CCTV, we:

• Only use carefully selected specialist service providers, where necessary.
• Will only hold your information in this way for as long as is needed.
• Will only share it in very limited circumstances, such as when we are permitted or required to comply with a legal or statutory requirement for example from the Police or Department of Work and Pensions.

Why do we use your information for this?
Using CCTV in our branches is necessary for our legitimate business interests. It helps us provide a safe and secure environment for people who visit us or carry out business in our premises. It also supports us in detecting and deterring any criminal activity.

The Data Protection Officer
London Mutual Credit Union
4 Heaton Road
Peckham
London
SE15 3TH

Updating this notice

We may update this notice from time to time. If we make changes, we will try to let you know but it is always a good idea to revisit this page when you can.

This notice was last updated on 25 May 2018.

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