Boom Community Bank is committed to protecting its members' privacy. This Notice sets out how we deal with your personal and financial information and how and when it may be shared with others. It applies to information we collect about:
- People who apply for and use our products and services, for example current members, local tenants and other customers
- Other people we deal with in the course of delivering our services, example: local authorities, registered social landlords, private landlords, employers
- Job applicants, current and former employees.
- Visitors to our website.
We have to hold your details to allow us to process your application or request for services and then to provide them and ensure that we are able to carry out our responsibilities. For example: as a member, we will hold the details which we obtain from you at the outset of your membership and records concerning share deposits and loan repayments and your conduct in relation to your membership.
How we use your personal information
Boom Community Bank may process, transfer and/or share personal information in the following ways:
For legal reasons:
- Confirm your identity
- Perform activities for the prevention of financial crime
- Carry out internal and external auditing
- Record basic information about you on a register of members
For the 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 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 and 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 interest:
- Recover any debts owed to us
For your legitimate interest:
We are owned by our members and not by external shareholders. We, therefore, keep all members informed of Credit Union news, changes and developments to our services in which they have a legitimate interest.
With your consent:
- Maintain our relationship with you, including marketing and market research (if you agree to them)
Sharing your personal information
We will disclose information outside the Organisation:
- 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 or 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 businesses
- Other parties for marketing purposes (if you agree to this)
- A bank account checking service with your consent
Retaining your information
Boom Community Bank 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 ended your membership.
Credit Reference Agencies and Fraud Prevention 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 at:
- Transunion at www.transunion.co.uk/crain
- Equifax at www.equifax.co.uk/crain
- Experian at www.experian.co.uk/crain
They may retain information for up to 6 years after any credit agreement between us has ended. When we share this information all parties conform to industry standards.
Credit Reference Agencies also share information about people with many financial organisations.
Their records can tell us:
- whether you have kept up with paying your bills, rent or mortgage, and other debts such as loans, phone and internet contracts;
- your previous addresses;
- information on any businesses you may own or have owned or directed;
- whether you are financially linked to another person, for example by having a joint account or shared credit;
- whether you have changed your name;
- whether you have been a victim of fraud.
Where you are financially linked to another person their records can provide us with details about that person’s credit agreements and financial circumstances.
They also use publicly available information to record information about people, including information from:
- The Royal Mail Postcode Finder and Address Finder;
- The Electoral Register;
- Companies House;
- The Accountant in Bankruptcy and other UK equivalents;
- The Insolvency Service and other UK equivalents;
- County Court Records.
This tells us, among other things:
- Your age, address and whereabouts;
- whether you are on the Electoral Register;
- whether you have been declared bankrupt;
- whether you are insolvent; and
- whether there are any County Court Judgements against you.
Credit Reference Agencies may also be Fraud Prevention Agencies.
We use this information to help us make sure we are lending our money responsibly and to help us decide whether a loan is appropriate for you. We cannot do this without:
- confirming your identity;
- verifying where you live;
- making sure what you have told us is accurate and true;
- checking whether you have overdue debts or other financial commitments; and
- confirming the number of your credit agreements and the balances outstanding together with your payment history.
We also have a duty to protect the Credit Union and the wider society against loss and crime, so we use and share Credit Reference Agency information:
- to identify, prevent and track fraud;
- to combat money laundering and other financial crime; and
- to help recover payment of unpaid debts.
We use information in this way to fulfil our contract to you, to meet our legal and regulatory responsibilities relating to responsible lending and financial crime, to protect the Credit Union from loss, to pursue our legitimate interests and to prevent crime.
We may use automated decision making in processing your personal and financial information to make credit decisions.
It is our policy to manually review automated decisions whenever possible. However, you have the right to request a manual review of the accuracy of any decision we make if you are unhappy with it.
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.
Fraud Prevention Agencies
We use your information to carry out checks for the purposes of preventing fraud and money laundering. These checks require us to process and share personal data about you.
The personal data can include information that you have shared with us in making your loan application, other information we have collected or hold about you, or information we receive from third parties such as Credit Reference Agencies.
We will share your:
- date of birth;
- contact details;
- financial information;
- employment details;
- Device identifiers, including IP address; and
- Any other information that it is in our legitimate interest to share in order to prevent or detect fraud, or that we are legally obliged to provide.
We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.
We process your data in these ways because we have a legitimate interest in preventing fraud and money laundering in order to protect our business and to comply with laws that apply to us.
Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, for up to six years.
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the loan or any other services you have asked for. We may also stop providing existing services to you.
A record of any fraud or money laundering risk will be retained by fraud prevention agencies and may result in others refusing to provide services, financing or employment to you. If you have any questions about this then please contact us.
Under data protection law, you have rights including:
- Your right to be informed - you have the right to be informed about the collection and use of your personal data.
- Your right of access - you have the right to ask us for copies of your personal information.
- Your right to rectification - you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure - you have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing - you have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing - you have the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability - you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
Rights related to automated decision-making and profiling - Boom Community Bank does not use an automated decision-making process for processing loan applications. To assist our decision, we will look 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 insolvency service
- Whether or not you are bankrupt
- Your age
You have the right to have the lending decision reviewed by a member of staff, express your point of view, obtain an explanation of the decision and challenge it.
Right to withdraw consent - You have the right to withdraw consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us by email, phone, or post if you wish to make a request.
If you are a member and you would like to change your marketing preferences, please email email@example.com
You may change your marketing preferences at any time.
How to complain
If you are unhappy with how we have used your data, you can make a complaint to us in writing at:
Boom Community Bank
17 Liverpool Gardens
Or email: firstname.lastname@example.org
You can also complain to the ICO if you are unhappy with how we have used your data.
Information Commissioner’s Office
Helpline Number: 0303 123 1113
ICO website: www.ico.org.uk
Changes to this policy
We update this Privacy Notice from time to time, and ideally, you should check it regularly here for updates. We will not alert you for every small change, but if there are any important changes to the Notice or how we use your information, we will let you know and, where appropriate, ask you for your consent.