Data Protection Statement

BLARNEY CREDIT UNION


DATA PROTECTION STATEMENT – GENERAL BUSINESS ACTIVITIES

1. OVERVIEW

We want to explain clearly how we process your Personal Data when you interact with Blarney Credit Union as a supplier, a website user, a candidate for a voluntary role or employment or as a visitor.

We collect and process personal data as we carry out the day-to-day business activities of running the Credit Union including dealing with suppliers, operating our website, securing our premises and carrying out recruitment related activities. This section of the data protection statement provides specific information relating to the processing of personal data in our general business activities.

2. WHO THIS DATA PROTECTION STATEMENT APPLIES TO?

This Data Protection Statement provides specific information relating to the following data subjects whose Personal Data we process:

  • business contact details including those of our customers, suppliers, partners, shareholders and

business prospects “Business Contacts”;

  • users/visitors to our Website “Website Users”; and
  • prospective employees /those applying for jobs at Blarney Credit Union “Candidates”; and
  • members of the public who pass by and/or visit Blarney Credit Union offices and whose images are captured on CCTV “Visitors”;

3. CATEGORIES OF PERSONAL DATA

We process the following categories of Personal Data. For each category we have included an example of the type of Personal Data that maybe part of that category:

Personal Data Category

Description

Identification Data

may include a person’s name, date of birth, driver’s license and passport

information.

Contact Data

may include a person’s email address, phone number and postal address

Communication Data

may include phone calls, email correspondence and hard copy correspondence. This includes recording of phone calls when you phone the

Credit Union.

Marketing Data

may include your contact data and any preferences in receiving marketing

from us and your communication preferences.

Recruitment Data

may include recruitment related data such as identification data, contact data, communication data, CV and job application data.

This may include employment history, skills/ experience, languages, educational history, qualifications, membership of professional associations, contact details of employer references/character references, licenses held,

interests and hobbies, languages, locations, nationality, passport, eligibility to work in certain jurisdictions, salary expectations, interview/screening

answers and notes.

Financial Data

may include payment related information or bank account details and

financial data received as part of the services that we provide.

Special Category Recruitment Data

If we interact with you for the purposes of a job with the Credit Union, we may collect recruitment data that is of a special category per the GDPR

definition.

CCTV Data

We operate CCTV cameras at some of our premises. If you pass by and/or

visit some of Blarney Credit Union’ premises, your image may be recorded

on CCTV.

Web Data

may include personal data provided on any forms on our website and, to the extent that it includes personal data, information on the type of device

you’re using, its IP address, operating system, referral source, length of visit,

page views and website navigation paths, as well as information about the

timing, frequency and pattern of your service use.

Social media data

We receive personal data about website users when they follow social

media links on our website.

 4. OUR PROCESSING ACTIVITIES

We use Personal Data to assist us in the operation of the company. Under data protection law, we must ensure that the purpose of processing is clear.

Purpose of Processing

     Categories of Personal Data

      Lawful Basis

Managing payments and administration of the contract including:

·      To carry out due diligence on suppliers prior to entering into a contract

·      to process payments to and from our business

·      to fulfil our legal/contractual obligations

·      to manage/respond to complaints/issues

·      Contact Data

·      Communication Data

·      Financial Data

·      Contract

·      Legitimate Interest

·      Legal Requirement

Recruiting staff including:

·      to interview the Candidate

·      to manage our database of Candidates

·      to contact you in connection with any job position we may have open

·      to check your suitability for the role

·      to fulfil the recruitment needs of the business.

·       Identification Data

·       Contact Data

·       Communications Data

·       Recruitment Data

·       Web Data

·       Special Category Recruitment Data

·      Legitimate Interests

·      Consent

·      Contract

Website delivery including:

·      to manage and respond to web forms

·      to promote our products and services

·      to administer the Website

·      To manage your website experience

·      To improve our website content

·      for internal operations, including support, troubleshooting, data analysis, testing, research, statistical and survey purposes

·      to ensure the safety and security of our website and our services.

·       Web Data

·       Contact Data

·      Legitimate Interests

·      Consent

Ensuring security of the Blarney Credit Union

premises

·       CCTV Data

·      Legitimate Interests

Social Media Account Management including:

·      To market our services to you through social media interactions

To respond to enquiries about our services

·       Contact Data

·       Correspondence data

·       Social media data

·      Consent

·      Legitimate Interest

Management of Corporate Affairs

·      to take minutes at board meetings

·      to contact shareholders/investors

·      to enter into partnerships and other commercial relations

to undertake appropriate due diligence

·       Identification Data

·       Contact Data

·       Communication Data

·       Financial Data

·      Contract

·      Legitimate Interest

·      Legal Obligation

To meet our regulatory obligations:

To comply with the Credit Union (Amendment) Bill 2023. Issuing AGM and Annual Accounts notification by email and/or text

·       Contact Data

·       Identification Data

·       Correspondence Data

·       Financial Data

·      Legal Obligation

 5. SOURCES OF PERSONAL DATA

BUSINESS CONTACT PERSONAL DATA

We collect Business Contact Personal Data from our business contacts including –suppliers, partners, consultants, shareholders and business prospects.

We source Business Contact Personal Data in order to serve the business relationship. We will only ever source Personal Data that is necessary and in a way that would be generally expected.

We receive Personal Data about Business Contacts from a variety of sources, as follows:

  • the Personal Data is often provided by the Business Contact as part of the business relationship;
  • the Personal Data may be collected from public sources;
  • the Personal Data may be collected indirectly from another person within the company of the Business Contact;
  • the Personal Data may be collected through our website;
  • the Personal Data may be collected indirectly from a website or from a third

  • To enable members to avail of AIS (Account Information Service) process to share their bank account transactions with us as part of a loan application. This process is carried out by an Independent Data Controller (Truelayer) and consent will be obtained by Truelayer.

CANDIDATE PERSONAL DATA

We will only ever source Personal Data in a way that would be generally expected.

We receive Personal Data relating to Candidates from a variety of sources. The primary source is from Candidates directly. Examples of the sources of Personal Data of Candidates are as follows:

  • the Candidate may send their CV to us with the intention of registering with us to be informed of potential job vacancies;
  • the Candidate may apply directly to a position advertised on our website;
  • the Candidates details may be provided by a member of staff or third party by way of referral; and
  • the Candidates details may be provided by a recruitment

WEBSITE USERS PERSONAL DATA

We receive information from you when you visit our website, when you complete an online form on our website, if you subscribe to our newsletter or if you follow us vis social media links on our website.

This information is collected from you as a result of your interaction with the www.Blarneycu.ie website.

We also collect information with your consent when we place cookies on your web browser. For more details please refer to our Cookie Statement.

SOCIAL MEDIA USERS PERSONAL DATA 

We collect information from you when follow our social media accounts, like, comment or reshare a social media post or when you communicate with us via messaging apps on social media platforms.

CCTV PERSONAL DATA

We may collect CCTV video footage of visitors to our premises.

6. RETENTION

In some circumstances it is not possible for us to specify in advance the period for which we will retain your Personal Data. In such cases we will determine the appropriate retention period based on balancing your rights against our legitimate business interests. We may also retain certain Personal Data beyond the periods specified herein in some circumstances such as where required for the purposes of legal claims.

Our retention policy is as follows:

Purpose of processing

       Categories of Personal Data

Retention Period

Relationship Management

·         Contact Data

·         Communications Data

·         Identification Data

·         Financial Data

24 months after completion of service delivery activities in the case where there is no further meaningful engagement.

Certain Personal Data may be retained for 7 years

Marketing & Sales

·         Contact Data

·         Communication Data

·         Marketing Data

·         Web Data

12 months in the case where no meaningful engagement or earlier in the case you unsubscribe.

Recruitment

·         Identification Data

·         Contact Data

·         Communications Data

·         Recruitment Data

·         Web Data

·         Special Category Recruitment Data

3 months for unsuccessful candidates

Website Delivery

·         Web Data

·         Contact Data

12 months or less

Security

·         CCTV Data

30 days

Management of Corporate Affairs

·         Identification Data

·         Contact Data

·         Communication Data

·         Financial Data

7 years unless required to retain indefinitely

In certain cases, we may retain Personal Data for longer than specified here if required under relevant laws.

Note that this section of the Credit Union Data Protection Statement relates only to how we process data relating to Blarney Credit Union general business activities.

We have Data Protection Statements that provide specific information about how we process your Personal Data when you interact with any of the following Credit Union Services including:

  • Member Accounts
  • Loan Accounts
  • Online Banking

Please see our General Data Protection section for more general information about our processing activities including marketing activities and information relating to (i) how to exercise your rights, (ii) who your Personal Data may be shared with (including cross border transfer); (iii) the security measures we have implemented and the contact details for the Data Protection Commission in Ireland.