This privacy notice explains how Harp and Crown uses any personal information we collect about you.
Harp and Crown is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, you can be assured that it will only be used in accordance with this Privacy Notice. This notice explains how we do this and tells you about your privacy rights, and how the law protects you.
What we collect:
Harp and Crown will collect information about you when you register or apply for membership of any of our services. We may also collect information when you voluntarily supply information to us, update your personal details, participate in surveys or offer feedback.
We may collect the following categories of information depending on the services you avail of:
Personal details;
Family details;
Health Details;
Financial details;
Legal information;
Employment details;
Lifestyle or social circumstances.
We collect this information to pursue the representation of you as a member; for example, providing you with a service or assisting you with a query. We must have a lawful basis on which to process your information. The lawful basis will be for one of the following reasons:
Where the use is for our Legitimate Interest - as Harp and Crown cannot reasonably perform its representation of members without processing their personal data, there is a reasonable expectation that Harp and Crown need to process members’ information, and a relevant and appropriate relationship between the Controller and Data Subjects.
We ask for your consent - Consent will only be relied upon where the individual is required to provide special category data, which includes information relating to race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, sex life or sexual orientation. Consent will be specific to the special category information requested.
We have a Legal Obligation - this may be in the event that we must comply with a legal obligation to supply information to regulatory authorities or law enforcement agencies.
We need to protect a Vital Interest – this will only be used in exceptional circumstances where processing is necessary to protect an individual’s life.
How we will use the information collected:
We collect personal information about you to manage your membership, and contact you if necessary. We use this information to provide the services and products requested, maintain records, to protect your shares under the Financial Services Compensation Scheme and to send you information on updates or renewals to services, or to tell you about new services or products available. Harp and Crown will not share your information for marketing purposes with any other companies.
In managing your membership, providing you with a service, or representing you in any way, it may be necessary for us to share your information with other agencies.
Who we may share your information with:
Police Service of Northern Ireland;
Legal Advisors;
Auditors and Business Advisors;
Family, associates or representatives of the individual whose personal data we are processing;
Ombudsmen and Regulatory Authorities;
Debt collection and tracing agencies;
Financial Services Compensation Scheme;
Credit reference agencies; and
Fraud prevention agencies.
Credit Reference Agencies information:
In order to process your application, we will perform credit and identity checks on you with one or more Credit Reference Agencies (CRAs). We may also carry out further periodic searches at CRA’s to allow us to manage your account with us.
To do this, we will supply your personal information to CRAs. This will include your name, date of birth and residential address. It may also include additional information such as your salary, previous residential addresses and other information you provide as part of your credit application.
The CRAs will match this information to the records they hold about you, and provide in return, both public information (including the electoral register) and shared credit information in relation to your financial situation and financial history.
CRA’s will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.
We will use this information to:
Assess your creditworthiness and whether you can afford to take the product;
Verify the accuracy of the data you have provided to us;
Prevent criminal activity, e.g fraud and money laundering;
Manage your account(s);
Trace and recover any debts; and
Ensure any offers provided to you are appropriate to your circumstances.
We will continue to exchange information about you with CRA’s while you have a relationship with us. We will also inform the CRA’s about your settled accounts. If you borrow and do not repay in full or on time, CRA’s will record the outstanding debt. This information may be supplied to other organisations by CRA’s
When CRA’s receive a search from us they will place a search footprint on your credit file showing ‘Credit Union’ that may be seen by other lenders.
Financial Services Compensation Scheme (FSCS):
Your shares are protected up to the value of £85,000 under the FSCS. In order to subscribe to the compensation scheme the credit union must provide a file when requested for testing and verification by FSCS. For this routine testing the file is provided with the credit union’s office address as each member’s home address. In the unlikely event that the credit union does fail this file would be sent to FSCS with members’ personal addresses via highly secured systems within the Bank of England’s network. This would be to ensure that members’ monies are compensated within 7 days in line with FSCS guidelines.
Security:
All the personal data you provide will be processed by our staff in the Harp and Crown, 18b Newforge Sports Complex, unless we need to transfer all or part of it to the agencies listed above. We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place robust physical, electronic and governance procedures to safeguard and secure the information we collect.
How long we will keep it:
We will retain your personal data as long as we require it to maintain and record membership of the services and products you avail of; or if there is a statutory requirement to do so.
Your Rights:
We want to make sure that your personal information is accurate and up-to-date, and you have the right to request a copy of the information that we hold about you.
You may ask us to correct or remove information you believe to be inaccurate. You also have the right to request the erasure of your data.
If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate this matter.
If you are not satisfied with our response, or believe we are processing your data in contravention of the law, you can complain to the Information Commissioner’s Office (ICO). www.ico.org.uk
The identities of the CRA’s, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRA’s are explained in more detail at:
Marketing Opt In
From time to time we wish to send members a marketing ezine (currently via Mailchimp) with latest news, product launches, competitions and more, which we feel will be of interest. Members can “opt in” to this via our website NEWSLETTER SIGNUP section or by emailing marketing@harpandcrown.co.uk. Members can opt out of marketing emails at any time by emailing marketing@harpandcrown.co.uk. It is important to note that this will also opt you out of routine SMS and written communications that we sometimes use to keep members up to date. We will never share a member’s personal information and email address with a third party for the purposes of marketing.
Our Data Protection Officer can be contacted at creditunion@harpandcrown.co.uk
This policy was approved by the Board of Directors on 24th November 2023 and will be reviewed at least annually.
