Holdfast Credit Union
Privacy Statement

Holdfast Credit Union is committed to protecting our members’ privacy. We require 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 for your consent.

We have implemented reCAPTCHA v3 on our site and it's use is subject to the Google Privacy Policy and Terms of Use. reCAPTCHA is only used to fight spam and abuse on our site.

Holdfast Credit Union may process, transfer and/or share personal information in the following ways:

For legal reasons

• To confirm your identity
• To perform activity for the prevention of financial crime
• To carry out our internal and external auditing
• To record information about you on a members’ register

For performance of a contract with you

• To deal with your account(s) or run any other service we provide to you
• To consider any applications made by you
• To carry out credit checks and obtain and provide credit references
• To 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 notifications of our general meetings or any Special meetings

For our legitimate interests

• To recover any debts owed to us

With your consent

• To maintain our relationship with you including marketing and market research (if you agree to them)

We will disclose information outside of Holdfast Credit Union

• 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 and public – to which they have access
• to any authorities if compelled 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 other members when they view the members’ register which contains details of members’ names, joining and leaving dates, and mailing addresses
• 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 Holdfast credit union business
• to other parties for marketing purposes (if you have opted in to this)

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.

Holdfast 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 HM Revenue & Customs which may transfer that information to tax authorities in countries where you or a connected person may be a tax resident.

Holdfast 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.

To read our policy for retaining members data please see the GDPR (General Data Protection Regulation) section below or contact us on 01376 516994.

Your rights under data protection regulations are:

• The right to access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object to data processing
• Rights related to automating decision-making and profiling
• The right to withdraw consent
• The right to complain to the Information Commissioner’s Office

We can update this Privacy Statement at any time and ideally you should check it regularly here for updates. We won’t alert you for every small change, but if there are any important changes to the Statement or how we use your information we will let you know and where appropriate ask for your consent.

Your rights explained

You have t the right to access your personal data and details of the purposes, 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 a copy of your personal data.

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 data about you completed.

In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include:

• the personal data is no longer needed for the purpose for which it was originally processed
• withdrawing consent you previously provided to process the information
• Objecting to the processing under certain rules of data processing law
• where the processing is for marketing purposes
• where the personal data was unlawfully processed

In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are:

• where you contest the accuracy of the personal data;
• where processing is unlawful but you oppose erasure;
• where we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims: and
• where you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data.

• with your consent;
• for the establishment, exercise or defence of legal claims; or
• for the protection of the rights of another natural or legal person.

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.

To the extent that the legal basis for our processing of your personal data is:

• consent: or
• that the processing is necessary for the performance of our contract with you,

To the extent that the legal basis for our processing of your personal data 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.

If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with Information Commissioner’s Office which is responsible for data protection in the UK.

You can contact them by:

Going to their website: https://ico.org.uk

Phone: 0303 123 1113

Post to:
Information Commissioner’s Office,
Wycliffe House,
Water lane,
Wimslow, SK9 5AF.

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 at info@holdfastcreditunion.co.uk or on 01376 516994. We will aim to respond to your request or query within one month or provide an explanation of the reason for our delay.