Privacy Policy

A credit union is a member-owned financial cooperative, democratically controlled by its members, and operated for the purpose of promoting thrift, providing credit at competitive rates, and providing other financial services to its members. Data collection, processing and use are conducted solely for the purpose of carrying out the abovementioned objectives.

This Privacy Notice is to provide you with information regarding the processing of information about you for account related purposes, lending and other general purposes.

Our contact details are:

Address: Tubbercurry & District Credit Union Ltd., The Square, Tubbercurry, Co. Sligo
Phone: 071 91 86297
Email: info@tubbercurrycu.ie

What personal data do we use?

We may collect, store and use the following categories of personal data about you:

Your name, address, date of birth, email, telephone, nationality, financial data, status and history, transaction data; contract data, details of the credit union products you hold with us, signatures, identification documents, salary, occupation, source of wealth, source of funds, Politically Exposed Status, accommodation status, mortgage details, bank account details, CCR reports, previous addresses, spouse, partners, nominations, health data, Tax Identification/PPSN numbers, passport details, driver licence details, tax residency, interactions with credit union staff and officers on the premises, by phone, or email, current or past complaints, CCTV footage etc.

We need all the categories of information in the list above to allow us to identify you, contact you, comply with our legal obligations and in order that we perform our contract with you.

In certain instances, an individual may supply us with information relating to another individual. This may occur in the following cases:

Bank statements provided where the account is in joint names,
Utility bills in joint names
Personal information contained in sets of Business Accounts

In these instances, it is the responsibility of the individual providing the data to ensure the other named individual/s are aware their data is being shared and do not object to this.

Purposes for which your data are processed

Account Opening:

We will use personal data in order to carry out the following functions related to opening an account:

To open and maintain an account;
To give consideration to an application prior to approval;
Verifying the information provided in the application;
To comply with our legal obligations, for example anti-money laundering, to identify connected borrower, to identify a politically exposed person;
To confirm tax residency for the purposes of the Common Reporting Standard;
To meet our obligations under the Credit Union’s Standard Rules;
To provide members with details of the Deposit Guarantee Scheme;
To contact members in respect of their accounts;
To contact members in relation to any operational matters within the credit union;
To record details of nominations and to process the nomination (subject to a valid nomination) and transfer any nominated property to the nominee(s);
To issue members with information on any product or service held at the Credit Union or to provide details of other services, products, offers or competitions that may be of interest to our members.

Loans: Applications, Administration and Arrears:

We will use personal data in order to carry out the following functions:

Assessing a loan application and determining creditworthiness for a loan;
Verifying the information provided in the application;
Conducting credit searches and making submissions to the Central Credit Register;
To purchase loan protection from ECCU;
To determine whether an applicant is a connected borrower or related party borrower in order to comply with Central Bank Regulations;
Administering the loan, including where necessary, to take steps to recover the loan or enforce any security taken as part of the loan;
To take steps to secure repayment of a loan such as processing a charge on a property;
Providing updates on loan products and services by way of directly marketing to members;
To contact members in relation to any transactions or missed payments on their account;
Meeting legal and compliance obligations and requirements under the Rules of the Credit Union;
To complete a submission to the Central Credit Register where a loan falls into arrears;
To thank members for completing their loan payments in full;
Where there is a breach of the loan agreement we may use the service of a solicitor to recover the debt. We will pass them details of the loan application in order that they make contact and details of the indebtedness in order that they recover the outstanding sum;

Guarantors: As part of the conditions of a loan, the appointment of a guarantor may be a requirement in order to ensure the repayment of a loan. In such instances, we have a legal and regulatory requirement to collect, process and store certain personal data of the guarantor. This will include data such as:

name, address, contact details, occupation, PPSN, salary and other relevant financial data.

The purposes for which we may process the data of the guarantor include:

ensure the terms of the loan agreement are met
to contact the guarantor if the loan falls into arrears or there is a change in the payments by the member that indicate a change in circumstances
to collect the debt
to carry our required credit searches
to carry out CCR checks and submissions (note: this is a legal requirement since 1^st February 2025)

The loan balance may be communicated to the guarantor at any time for the duration of the loan. The details of the guarantor will be retained in line with the loan which is 7 years from the date the loan is paid in full.

General Administration and Operation

We will use personal data to assist it in carrying out the following:

To contact members about their account in the Credit Union for any reason;
To contact members, using any contact method supplied, about reactivating dormant accounts;
To record CCTV footage to ensure the safety and security of our staff, members, volunteers and any other third parties visiting our premises, to resolve complaints and improve service standards;
To collect certain personal data if members attend the AGM such as name, account number and signature;
To issue obligatory information to members (eg. AGM notifications, annual accounts and certain reports);
To collect member preferences regarding marketing materials;
Providing updates on our products and services by way of directly marketing to members;
From time to time we may collect a small amount of personal data for entry into competitions and prize draws e.g. Car Draw. We will only use this data for the purpose of determining entry and selecting a winner for the competition/draw.

Online Operations

We offer a number of online services to our members and prospective members. In order to avail of our online services, members or prospective members must provide certain personal information.

This information is required to:

Login to the online platform;
Use our Mobile App;
Transfer funds;
Manage payments and payees;
Apply for a loan;

Specific Terms and Conditions apply to the usage of our online platforms, and we would advise users to read these and contact us with any queries.

Nominations

Under credit union legislation, members aged 16 or over may nominate one or more individuals to receive property in their credit union account (such as shares) on their death. A member can change or revoke their nomination at any time during their membership, and a nomination may also be automatically revoked by marriage, civil partnership, or by the death of a nominee before the member. The Credit Union is required by law to keep a record of nominations (and any changes or revocations), but the validity of a nomination can only be confirmed after the member has passed away. For this reason, we cannot contact nominees during the member’s lifetime to confirm that a nomination exists.

When a nomination becomes effective, we may need to collect and process certain personal information about the nominee, such as name, address, relationship to the member, contact details, identification, bank details, and any other information necessary to verify identity and transfer the nominated property. This information may be obtained directly from the nominee or from the nomination form completed by the member. We may share such information with professional advisers (e.g. solicitors, auditors), regulators, the Irish League of Credit Unions (ILCU), or others involved in administering the deceased member’s estate, where required by law. The nominee’s name is permanently retained in the register of nominations, while nomination forms and related documentation are retained for up to seven years after the member’s passing, in line with statutory limitation periods.

Data Sharing and Data Transfers

We do not sell any personal information, nor do we share it with unaffiliated third parties unless we are required to do so by law. We will ensure that any information passed to third parties conducting operational functions on our behalf will be done with respect for the security of personal data and will be protected in line with data protection law.

Ways in which we may share personal information include:

With official bodies including, but limited to:
- the Irish League of Credit Unions (ILCU) under the ILCU Standard Rules and the League Rules which govern the operation of Credit Unions;
- ECCU Assurance DAC who provide Loan Protection and personal data must be shared in order to administer claims or deal with insurance underwriting;
- Central Credit Register who provide financial institutions with credit details relating to a member’s eligibility for a loan;
- The Central Bank of Ireland enforce certain reporting, compliance and auditing on Credit Unions.
- Government Departments such as Department of Finance and the Department of Social Protection may require the Credit Union to share certain personal information in order to meet legislative and regulatory requirements;
- The Revenue Commissioners impose certain reporting obligations on Credit Unions under the Common Reporting Standards in relation to tax residency and the in respect of dividend or interest payments to members.
- The Financial Intelligence Unit require that we submit information to them in relation to suspicious transactions.
To engage external IT providers so as to ensure the security of our IT systems in order to protect all personal data;
With our insurers or assessors when providing or reviewing information in the event of an incident occurring;
To engage professional services of third parties, such as auditors, solicitors or any other such business advisers. Any such parties are bound by confidentiality;
We reserve the right to report to law enforcement any activities that we, in good faith, believe to be illegal;
We may share relevant personal data with the Decision Support Service where required by law or where necessary to fulfil our legal obligations in relation to supported decision-making arrangements;
We may share relevant personal data with our fraud monitoring service provider, NEXI, to enable the monitoring of transactions for suspicious activity and the prevention of fraudulent or unauthorised payments;
As required by the European Payments Council’s Verification of Payee Scheme, we share IBAN and Account Names with Banfico, acting as the Routing & Verification Mechanism, to verify payee information and return a match result;
With any relevant, authorised third parties as part of a merger or acquisition, any such parties will be bound by a duty of confidentiality;
To provide information to An Garda Síochána (e.g. CCTV footage) or other Government bodies or agencies when required to do so by law; and
To transfer data to another credit union where we have received a request, authorised by you, from another credit union to do so.

There may be circumstances where we transfer your personal data outside the EEA, such as when we use the services of online platforms or where we use a cloud-based IT system to hold your data. We safeguard your data by ensuring a minimum of one of the following safeguards is in place:

a contract based on “model contractual clauses” (also called Standard Contractual Clauses) approved by the European Commission, obliging them to protect your personal data;
Binding Corporate Rules approved by relevant data protection authorities, ensuring your data is protected within a group of companies; or
with companies located in a third country approved by the European Commission under an adequacy decision, such as the UK.

Where any of our suppliers engage the service of sub-processor to process data of which we are a Data Controller, our due diligence measures will include an assessment of this processor, in particular where the processor is located outside the EEA. Appropriate security measures and contractual agreements are in place to protect your data whenever it is shared with any third parties.

Lawful Basis for Processing Personal Data

We are obligated to define a lawful basis for processing personal data. Below is a summary of our use of personal data and the lawful basis we rely on for the processing different categories of data for different purposes.

Article 6.1(b) “processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract”