Privacy Notice

This privacy notice applies to individuals who use our website at www.castlecommunitybank.co.uk (“Website”) or any of our business services (including the provision of savings accounts, loans and/or other financial services), and/or individuals who contact us by telephone, e-mail or other means (including other electronic means). Our Website is not intended for children and we do not knowingly collect any personal data relating to children.

1. Who we are

North Edinburgh and Castle Credit Union LTD (trading as Castle Community Bank), company number 019CUS and with registered address at 49 Great Junction Street, Edinburgh, EH6 5HX is a registered Credit Union. CCB is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority (Register number 213877) and the Prudential Regulation Authority.

We are a controller for the purposes of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 (the UK GDPR), the Data Protection Act 2018 and related data protection legislation.

Our Data Protection Officer is our Chief Operating Officer who is responsible for overseeing questions in relation to this privacy notice.

2. How to contact us

If you have any questions about this privacy notice or our data protection policies generally, please contact us:

By post: 49 Great Junction Street, Edinburgh, EH6 5HX

By email: info@castlecommunitybank.co.uk

By phone: 0131 466 5006

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

3. Privacy notice

We are committed to protecting your personal data and your privacy. This privacy notice sets out the basis on which any personal data we collect from you, or that you provide to us, or that we acquire through a third party, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Before we process your personal data, we are obliged to inform you of who we are, why we need to process your personal data, what we will do with your personal data and to whom we will pass your personal data.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

This privacy notice does not apply to our employees, workers, volunteers, secondees and consultants.

This version of our privacy notice was last updated on 7 November 2024.

4. What personal data do we collect and process?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity of the individual has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, photographic proof of your identity, marital status, title, date of birth, social media identifier and gender.
Contact Data includes home or work address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
Special Category Data includes health data, ethnicity, religious beliefs and sexual orientation.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
Employment Data includes job title and role.
Usage Data includes information about your visit and how you use our Website.
Technical Data includes information about the device you use to access the Website.

We may collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

5. How is your personal data obtained?

We may obtain or collect your personal data through:

*Source*	*Example*
Direct interactions with you	You provide us with your personal data when you fill out forms or correspond with us by post, phone, e-mail or through our Website including when you: · enquire about our services; · register for our services; · create an account on the Website; · visit any of our branches; · complete any surveys; · request marketing to be sent to you; or · give us feedback or contact us.
Automated technologies or interactions	Technical Data and Usage Data relating to your interaction with the Website or our other websites may be collected using cookies or other similar technologies.
Third parties and publicly available sources	We may receive your personal data from an organisation who employs or engages you.
	We may receive references and other personal data relating to you from third party organisations or professional advisers. Such third party organisations include fraud prevention agencies to check and verify your identity (and the identity of any other individual named on your application) and collect your credit report (and any other individual named on your application).
	We may obtain your personal data, in particular contact, financial or transactional details, from third-party providers of payment and credit card services or from providers of delivery services.
	We may obtain your personal data from the other applicant where you are a joint applicant.
	We may obtain your personal data from publicly available sources such as Facebook, LinkedIn or X (formerly Twitter).

6. Failure to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform services for you.

7. Marketing

If you are an individual user not using our services for your business purposes, we will only provide you with direct marketing communications where you have consented to receive such communication or you have contacted us directly to request specific information about our services. You can subscribe to such marketing communications, and you can adjust your marketing preferences at any time by contacting us at info@castlecommunitybank.co.uk or 0131 466 5006.

If you represent another business, we may provide you with direct marketing communications where we feel that this may be relevant to your business (provided that you have not opted out of such communications). When we use your personal data for such purposes, we do so on the basis that it is in our legitimate interests to pursue direct marketing, provided that it constitutes fair processing of your personal data to do so.

You can also opt-out or unsubscribe from all or some of these marketing communications at any time by contacting us at info@castlecommunitybank.co.uk or 0131 466 5006.

Where you opt out of receiving these marketing communications, this opt-out will not apply to personal data provided to us for any other purpose.

8. How will we use your personal data?

Personal data may be processed by us where you consent to the processing or where that processing is necessary for 1) the performance of a contract with you and/or to provide services to you; or 2) compliance with a legal obligation to which we are subject; or 3) the purposes of our legitimate interests (or those of a third party).

Legitimate interests means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Where we process your special category personal data, this will be with your explicit consent or where that processing is 1) necessary to protect your vital interests or the vital interests of another natural person where you or such other natural person are physically or legally incapable of giving consent; or 2) in relation to a legal claim; or 3) in relation to personal data which you have made public; or 4) necessary for public interest reasons; or 5) in accordance with a condition in the Data Protection Act 2018 which allows us to undertake such processing.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground or grounds we are relying on to process your personal data.

Purpose/Activity	Type of data	Lawful basis for processing (including basis of legitimate interest)
Where you use our Website as a registered user	All data	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us and to manage customer relationships) (c) Necessary to comply with a legal obligation (d) With your consent where we provide marketing information to you and you are an individual user not using our services for business purposes (e) With your explicit consent in respect to special category personal data (f) Necessary for our legitimate interests (to maintain network security and administer the functionality of the Website) (g) Necessary for our legitimate interests (to maintain Website relevance for registered users)
Where you visit one of our branches.	a) Identity (b) Contact (c) Financial (d) Transaction (e) Employment (f) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us and to manage customer relationships) (c) Necessary to comply with a legal obligation (d) With your consent where we provide marketing information to you and you are an individual user not using our services for business purposes (e) With your explicit consent in respect to special category personal data
Where you visit our Website and are not a registered user of the Website	(a) Usage (b) Technical	(a) Necessary for our legitimate interests (to maintain network security and administer the functionality of the Website) (b) Necessary for our legitimate interests (to maintain Website relevance for visitors to our Website)
Where you contact us by phone or email or by other means	(a) Identity (b) Contact (c) Employment (d) Marketing and Communications	(a) Necessary for our legitimate interests (to communicate with you) (b) Necessary to comply with a legal obligation (c) With your consent where we provide marketing information to you and you are an individual and not a business contact
To establish, exercise and defend our legal rights	All data	Necessary for our legitimate interests (in protecting our legal rights)
Sharing your personal data	All data	(a) Performance of a contract with you where sharing your personal data is necessary for the contract (b) Necessary for our legitimate interests (to develop and improve our services, maintain network security and defend our legal rights) (c) Necessary to comply with a legal obligation (d) Where you are providing information for a third party, we will share your personal data with the third party where you have provided your consent for sharing (e) With your explicit consent in respect to special category personal data

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using our contact details above.

9. With whom do we share your personal data?

9.1. Sharing with processors

We use certain third-party service providers as processors, and therefore, in the course of providing our services, we may share your personal data with these third parties, including:

*Third party processor*	*Why*
Amplifi Capital UK Limited T/A My Community Finance	To provide financial services to you

We do not allow our processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

9.2. Sharing with other controllers

There may be circumstances in which we need to share your personal data with certain third parties who are also controllers under the applicable data protection legislation. The third parties to which we may transfer your personal data include:

*Third party controller*	*Why*	*Name of third party controller*
Professional advisers including lawyers, accountants, auditors and insurers	To receive legal, accountancy, insurance and other professional services
Banks and financial advisers	To receive financial services and advice
Service sub-contractors and partner companies	Where relevant to services that we provide to you
Fraud prevention agencies and credit reference agencies (CRAs)	So we can comply with our legal obligations (please see section 10 below)	TransUnion Experian Equifax CIFAS
Acquirers of all or part of our business or undertaking	To allow us to sell or merge all or part of our business or undertaking to a third party
Any relevant regulatory authority or law enforcement agency (including the ICO and HM Revenue & Customs), courts and tribunals	To comply with our legal obligations and to comply with any reporting obligations

10. How credit reference and fraud prevention agencies use your personal data

When you apply to us for a loan, we will check the following records about you (and others where applicable):

our own records; and
information in the public domain for the purpose of identifying any information relevant to your application, including but not limited to information you have made publicly available on social media or other websites.

Credit Reference Agencies

In order to process your application, we will perform credit and identity checks on you with one or more CRAs. Where you use our banking services, we may also make periodic searches at CRAs to manage your account with us. To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs 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 our product(s) and service(s);
verify the accuracy of the data you have provided to us;
prevent criminal activity, fraud and money laundering;
manage your account(s);
trace and recover debts; and
ensure any offers provided to you are appropriate to your circumstances.

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.

If you are making a joint application or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files for a disassociation with the CRAs to break that link.

The identities of the CRAs, 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 CRAs are explained in more detail at:

https://www.experian.co.uk/legal/crain/.

You can contact the CRAs currently operating in the UK. The information they hold may not be the same so it is worth contacting them all. They will charge you a small statutory fee.

Their contact details are:

TransUnion LLC – email: UKConsumer@transunion.com or call 0330 024 7574 or visit transunion.co.uk or write to TransUnion Consumer Services Team, PO Box 647, Unit 4, Hull, HU9 9Q;
Equifax PLC – email: help.equifax.co.uk or write to Equifax Ltd, Customer Service Centre, PO Box 10036, Leicester, LE3 4FS or visit equifax.co.uk
Experian – email: ins.experian.co.uk or write to Customer Support Centre, PO Box 9000, Nottingham, NG80 7WF or call 0800 013 8888 or log on to experian.co.uk

Fraud Prevention Agencies

The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be found by visiting Fair Processing Notices for Cifas

11. International transfers

We generally do not transfer your personal data out of the UK. However, whenever we are required to transfer your personal data out of the UK (for example where a third party supplier is located outside of the UK), we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented, including any of the following:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government.
Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in UK.
You have provided your explicit consent to the transfer of your personal data outside of the UK.
The transfer is necessary for the purposes of performing a contract between us and you (the data subject).

Where you use the Website in a country outside the UK, your personal data will be transferred to and processed in the country from where you have accessed it. You acknowledge and agree that such a transfer of your personal data outside the UK is entirely your responsibility.

12. Automated decision making and profiling

We use industry standard automated credit scoring to make decisions., in other words, we use technology that can evaluate your personal circumstances and other factors to predict risks and outcomes. This may also be known as profiling. The automatic decision-making process considers various factors, such as your income, residency, financial position, fraud and other risk and relevant factors. We do this to speed up the loan application process for suitable borrowers. This is necessary for our ‘legitimate interest’ and meeting our legal responsibilities. If you meet with certain pre-determined criteria, our computer systems will automatically approve and process your application. If we determine that you pose a fraud or money laundering risk based solely on automated decision-making, we may refuse to provide the requested services or financing to you, or we may stop providing existing services to you.

If you want to know more about the rights you have about automated decision making, please contact us using the details above.

13. How long do we retain your personal data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

For tax purposes, we retain basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.

14. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and the Information Commissioner’s Office of a breach where we are legally required to do so.

15. Your rights

Your personal data is protected by legal rights, which include your rights to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, following your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: if you want us to establish the data’s accuracy; where our use of the data is unlawful but you do not want us to erase it; where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party (data portability). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of these rights, please contact us using the details above.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.