This statement describes how we process your personal information when you apply to become a member of Aviate Credit Union. Please take the time to read it carefully. This data protection statement should be read in conjunction with our data protection statement which applies to all our products and services which is available at www.aviatecu.ie.
You have a number of rights in relation to your information including the right to object to processing of your personal information where that processing is carried for our legitimate interests and for direct marketing.
Information about us
The terms “we” and “our” to refer to Aviate Credit Union. We are the data controller of the personal data which you provide to us on this form.
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this data protection statement and our approach to privacy. The DPO can be contacted at: Data Protection Officer, Aviate Credit Union, Cloghran House, Corballis Way, Dublin Airport, Co Dublin, K67 F3X2
Information we process about you
The information we process about you includes information to identify you, including your contact information; your financial details/financial circumstances; information about your transactions and use of our products and services; information about you provided by others e.g. your parent or guardian; information which you have consented to us using; and CCTV images at our branches.
The purpose and legal basis for processing your information.
We collect your personal information for a number of purposes and rely on a number of different legal bases to use your personal information.
a) To enter into and perform a contract with you:
Before you can become a member of the credit union we need to collect personal information from you in order to assess your application for membership and enter into a contract of membership with you and provide you with the benefits of membership.
We need to process your personal information in order to manage your accounts, your shares you hold in us, and products you hold with us and to assess your various applications for products and services, such as loans and budget schemes including, where applicable making decisions on your credit worthiness. We may obtain this personal information from you and in some circumstances from third parties.
We may also use your personal information to arrange insurance for you as an insurance intermediary. If you choose to enter into the car draw, we will use your personal information to enter you into the car draw and where you are a winner your name will be published on our website as a winner and on our social media and other digital media channels. In addition under the rules of the car draw your name will be provided to other entrants on request, within a certain period.
b) To comply with our legal obligations
We are required to process your personal information to comply with certain legal obligations to which we are subject, including:
To meet our obligations under the Credit Union Act 1997 (as amended) and other financial services legislation and codes of practice. This may involve sharing your personal information with the Central Bank, where we are required to do so and contacting you about various matters as required under the Credit Union Act 1997 (as amended) such as annual general meetings and election of officers.
Providing information to an gardai siochana, the Revenue Commissioners, the Central Bank and other enforcement agencies under various pieces of legislation to which we are subject.
To verify your personal information provided to us and to meet our legal and compliance obligations, including detecting and preventing money laundering, tax avoidance, finance of terrorism
To supply information to the Central Credit Register as required by law.
c) For our legitimate business interests
Where we process your information for our legitimate interests, we ensure that there is a fair balance between our legitimate interest andyour fundamental rights and freedoms.
We may use your personal information to manage our everyday business needs, including accounting, internal reporting needs, andmarket research, to progress and respond to legal claims, to ensure appropriate IT security and to prevent fraud, in our legitimate interest.
Our legitimate interest is the effective management of our business.
We may use your personal information to assess your creditworthiness prior to providing any funds to you by way of a loan overdraftfacility or otherwise, in our legitimate interest. Our legitimate interest is to ensure financial stability of the credit union.
We may use your personal information for direct marketing purposes to advise you of products and service we feel may interest you in our legitimate interest. Our legitimate interest is to connect with our members and to inform our members of various products and services which we provide. You can opt out of the receipt of direct marketing at any time.
d) With your consent
We sometimes process sensitive personal information, such as information concerning your health when you apply for certain products or services. Where we do so we will obtain your explicit consent, This consent can by withdrawn at any time by using the contact details of the DPO set out above.
Where you consent, we will provide access to others, who you authorise, to have access to your account. This consent can be withdrawn at any time.
Failure to provide information
Where we need to collect personal data by law, or under the terms of a contract with you and you fail to provide that data when requested we may not be able to perform the contract we have or are trying to enter in to with you (for example we require certain information from you in order to fulfil our requirements under both Irish and European Anti-Money Laundering Legislation before we can allow you to become a member of the Credit Union. As such we may not be able to complete your application for membership with us but we will notify you of this at the time if this is the case.)
Your information and Third Party Service Providers
Third Party Service Providers: We may share your personal information with third party service providers that perform services and functions at our direction and on our behalf such as our accountants, IT service providers, printers, debt collection agencies, valuers, lawyers and other business advisors, marketing companies who carry out marketing campaigns on our behalf and providers of security and administrative services.
Potential sale or merger of the Credit Union: we may also transfer your personal information to companies we plan to merge with or be acquired by.
An Garda Síochána, government bodies, the Central Bank or other government officials: we may share your personal information with an Gardaí, or other government bodies or agencies including but not limited to the Central Bank and the Revenue Commissioners, where required to do so by law.
Credit referencing agencies; we may disclose your information to credit referencing agencies for the purposes of carrying out a credit history check. We also provide these agencies with details regarding products and services you have with us and your repayment records.
The Central Credit Register; we may transfer your personal information to the Central Credit Register. This is a centralised system that collects and stores information about your loans and budget account. We will provide information about your products and services and details of your repayment history.
Vehicle Provider: Where you win the car draw we will provide your name and contact details to the provider of the vehicle who will contact you directly.
Third Parties: We may provide your information to third parties to facilitate transactions at your request, such as to make payments to third parties, to obtain foreign currency from our foreign currency provider (who may contact you to advise that your foreign currency is ready for collection) to arrange insurance for you in our capacity as an insurance intermediary. We may also provide information to any third party at your request.
ECCU: Where your loan is insured through ECCU we will provide your personal information to ECCU.
Storage Periods
We will retain your personal information for the purpose of satisfying any legal, accounting or reporting requirements. We may hold your personal information for a period of seven years from the date of completion of any contract with you, by reference to the statute of limitations for a legal claim under contract. We may hold your personal information for longer if required to do so by law.
Transfers outside the European Economic Area
We may transfer your personal data outside the European Economic Area. These countries do not always afford an equivalent level of privacy protection and in such circumstances we take specific steps, in accordance with data protection law and to protect your personal information. In particular, for transfers of personal data, outside the EEA where there is no adequacy decision by the European Commission we may rely on contractual protection approved by the European Commission.
How we use Automated Processing
We may analyse your personal information by automated means to make assessments on your creditworthiness and repayment capacity when you apply for a product or service. We will use this analysis to assist us in making a decision on whether to provide you with credit such as a loan or overdraft facility. We do not make decisions solely based on automated processes.
We may also use automated processing to assist in compliance with our legal obligations in connection with prevention of, money laundering, fraud and terrorist financing.
Your Rights.
You have several rights under data protection law in relation to how we use your personal information. You have the right, free of charge, to;
1. Request a copy of the personal information we hold about you.
2. Rectify any inaccurate personal data we hold about you.
3. Erase personal information we hold about you.
4. Restriction of processing of your personal information.
5. Object our use of your personal information for our legitimate interests, including profiling.
6. Receive your personal information in a structured commonly used and machine readable format, and to have that data transmitted to another data controller.
7. Where the processing is based on consent, the right to withdraw consent.
8. Object to us processing your information for direct marketing at any stage.
These rights are in some circumstances limited by data protection legislation. If you wish to exercise any of these rights please contact us using the contact details contained in this form. We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further period of two months and we will explain why.
You also have the right to lodge a complaint to the Office of the Data Protection Commission. Please see www.dataprotection.ie
