Introduction
Welcome to the Ulster Community Investment Trust Ltd (“UCIT”) and Ulster Community Investment Trust (Ireland) (“UCIT Ireland”) (together “Community Finance Ireland”) privacy notice.
Community Finance Ireland respects your privacy and is committed to protecting your personal data. This privacy notice will let you know how we look after your personal data when you visit our website, when you use our services and tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are
1.1 Purpose of this privacy notice
This privacy notice aims to give you information on how Community Finance Ireland collects and processes personal data we collect from you or that you provide to us or that we obtain from third parties. This personal data may be obtained through the provision of our services in accordance with loan documentation you enter into with us or any company we are associated with, through our clients and potential client’s use of the website (http://communityfinanceireland.com/), any loan application forms you complete, or through other direct communications between us and our clients or potential clients.
The website and our services are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice (a copy of which can be obtained upon request) and any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
1.2 Controller
Ulster Community Investment Trust Ltd and Ulster Community Investment Trust (Ireland) are joint controllers and responsible for your personal data (collectively referred to as “Community Finance Ireland” “UCIT”, “we”, “us” or “our” in this privacy notice). Please see section 10 for further information on the joint controller relationship between UCIT and UCIT Ireland.
We have appointed a data protection lead who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection lead using the details set out below.
1.3 Contact details
Full name of legal entities:
Ulster Community Investment Trust Ltd
Ulster Community Investment Trust (Ireland)
Data Protection lead:
Barry Connolly
Group Chief Financial Officer & Data Protection Officer
Email addresses:
hello@communityfinanceireland.com
Postal addresses:
NI: 6th Floor Glengall Exchange, 3 Glengall Street, Belfast, Co. Antrim, BT12 5AB
ROI: Unit 16, Ardee Business Park, Hale St, Ardee, Co. Louth, A92X N79
Telephone numbers:
NI: 02890315003
ROI: 041 685 8637
Complaints
Depending on the jurisdiction which you are based, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) which is the United Kingdom’s supervisory authority for data protection issues (www.ico.org.uk) or the Data Protection Commission which is the Republic of Ireland’s supervisory authority for data protection issues (https://www.dataprotection.ie/).
We would, however, appreciate the chance to deal with your concerns before you approach the ICO or the Data Protection Commission so please contact us using the details set out above in the first instance.
1.4 Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 30 November 2022. Prior versions can be obtained by contacting us.
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.
1.5 Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
1.6 If you fail to provide personal data
Where we need to collect personal data by law, through the loan application form on our website or to enable you to register on our website and you fail to provide that data when requested, we may not be able to process your loan application or register you on our website. In this case, we may have to reject your loan application but we will notify you if this is the case at the time.
2. How is your personal data collected?
2.1 We use different methods to collect data from and about you including through:
(a) Direct interactions. You may give us your Identity Data, Contact Data, Financial Data and Transaction Data and Marketing and Communications Data by filling in forms or by corresponding with us via our website or by post, phone, email or otherwise.
(b) Automated technologies or interactions. As you interact with our website, we may automatically collect Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookies policy on our website for further details.
(c) Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
(i) Usage Data from analytics providers;
(ii) Identity Data and Contact Data from publicly availably sources such as Companies House / Companies Registration Office based inside the EU.
2.2 The types of data we collect about you
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 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 means first name, maiden name, last name or similar identifier, title, gender.
- Contact Data means residential address, email address and telephone numbers.
- Financial Data means bank account details.
- Transaction Data means details about payments to and from you and details of loans you have entered into.
- Profile Data means your username and password.
- Usage Data means information about how you use our website, products and services.
- Marketing and Communications Data means your preferences in receiving marketing from us and your communication preferences.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.3 Purposes for which we will use your personal data
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 have also identified what our Legitimate Interests are where appropriate.
Note that 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 using the details set out in 1.3 if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of Legitimate Interest |
| To register your company as a new client for the purposes of a loan | (a) Identity Data (b) Contact Data | (a) Performance of a Contract with you (i.e. the loan) |
| To process and deliver the services including: (a) Manage fees and charges (b) Collect and recover money owed to us | (a) Manage fees and charges (b) Collect and recover money owed to us (a) Identity Data (b) Contact Data (c) Financial Data (d) Transaction Data | (a) Performance of a Contract with you (i.e. the loan) (b) Necessary for our Legitimate Interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) notifying you about changes to our privacy policy (b) asking you to leave a review or take a survey | (a) Identity Data (b) Contact Data (c) Usage Data (d) Marketing and Communications Data (e) Profile Data | (a) Performance of a Contract with you (b) Necessary for our Legitimate Interests (to study how clients use our services, to develop them and grow our business) |
| To enable you to complete a survey. | (a) Identity Data (b) Contact Data (c) Usage Data (d) Marketing and Communications Data | (a) Necessary for our Legitimate Interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity Data (b) Contact Data (c) Usage Data (d) Marketing and Communications Data | Necessary for our Legitimate Interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, client relationships and experiences | (a) Usage Data | Necessary for our Legitimate Interests (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity Data (b) Contact Data (c) Usage Data (d) Marketing & Communications Data | Necessary for our Legitimate Interests (to develop our products/services and grow our business) |
| To send you a seasonal card | (a) Identity Data (b) Contact Data (c) Marketing & Communications Data | Necessary for our Legitimate Interests (to develop our products/services and grow our business) |
3. How we use your personal data
3.1 We will only use your personal data when the law allows us to.
Most commonly, we will use your personal data in the following circumstances:
(a) where we need to process your loan application;
(b) where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
(c) where we need to comply with a legal or regulatory obligation.
Please see paragraph 2.3 (purposes for which we will use your personal data) to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the details set out in 1.3.
3.2 Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can ask us to stop sending you marketing messages at any time.
3.3 Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the UCIT group of companies for marketing purposes.
3.4 Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us using the details set out in 1.3.
3.5 Cookies
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy on our website.
3.6 Change of purpose
We will only use your personal data for the purposes for which we collected or received 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 the details set out in 1.3.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. Disclosures of your personal data
4.1 We may share your personal data with the other members of the Community Finance Ireland group who are based in the United Kingdom and the Republic of Ireland and provide IT and system administration services so that leadership reporting can be undertaken.
4.2 We require any other members of the Community Finance Ireland group based in the United Kingdom and the Republic of Ireland whom we share your personal data with to respect the security of your personal data and to treat it in accordance with the law.
5. International transfers
5.1 We do not transfer your personal data outside the EEA and UK.
6. Data security
6.1 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.
6.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6.3 Data Storage
Our current IT system is comprised of 3 Servers (Virtual Machines)
- Main Application Servers x2 in Head Office, Belfast
- To Wasabi Cloud Storage. The physical location of the data storage is Amsterdam, Netherlands in fully secure data centres that are certified for SOC-2, ISO 27001, and PCI-DSS. Staffed 24/7/365 with onsite security. Data storage is automatically encrypted at rest, HTTPS secure upload/download used and immutable storage options at the bucket and object level. Management access is via Multi-Factor Authentication (MFA), Enterprise Single Sign-On (SSO) options and Identity & Access Management (IAM) policies.
6.4 Data Sharing
When CFI and the credit union are collaborating in the provision of a community loan, there will be sharing of information between CFI and the credit union with respect to the loan and its ongoing performance, as specified in the terms and conditions of the loan offer.
6.5 Website Tracking
We use Lead Forensics in order to optimise our service and your experience. Lead Forensics uses a small piece of code, much like Google Analytics, which tracks IP addresses visiting our website (processed during your session and stored in a de-identified form) and geographic location (country & county only). We will only use website tracking to obtain information on the location of our visitors e.g. in which county in NI and / or ROI.
In order to comply with GDPR, explicit consent will be sought from end-users before tracking, via cookies on our website, continued transparency will be provided around our tracking practices and there will be secure storage and documentation of end-user consents.
For further information, please refer to our Cookie Policy and Terms & Conditions.
7. Data retention
7.1 How long will you use my personal data for?
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.
We will retain your personal data for the duration of our business relationship and afterwards, for up to six years, that which is relevant for our legitimate business purposes, in accordance with UCIT policy or as otherwise required by applicable laws and regulations. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you). By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease to be clients for tax purposes. In some circumstances you can ask us to delete your data: see paragraph 10(c) below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Your legal rights
8.1 Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
(a) 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.
(b) Request correction of your 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.
(c) 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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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, at the time of your request.
(d) 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) Request transfer of your personal data to you or to a third party. 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.
(g) Right to 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 the rights set out above, please contact us using the details set out in 1.3.
8.2 No fee usually required
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.
8.3 What we may need from you
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.
8.4 Time limit to respond
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.
9. Glossary
Legitimate Interest 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.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract, in this case a loan agreement
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
10. Joint Controller Statement
This paragraph explains the nature of the relationship between UCIT and UCIT Ireland. For the purposes of Article 26 of the GDPR, it sets out the legal relationship between us in relation to your personal information and our respective responsibilities to ensure we comply with the law.
Community Finance Ireland is an all-island organisation and it is important for the operation of our business that your personal information in regards to loan applications is transferred between UCIT and UCIT Ireland to enable us to provide our services to you and for other purposes as set out in 2.3.
In legal terms, in relation to the personal data of our clients, UCIT and UCIT Ireland are “joint controllers”. This means that we may jointly determine the purposes and means of processing your personal data. It also means that UCIT will determine the purpose for which UCIT uses your personal data and UCIT Ireland which has collected your personal data will determine the purposes for which it uses your personal data.
UCIT and UCIT Ireland are responsible for the collection and processing of your personal data in accordance with this privacy policy. It sets out comprehensively what information Community Finance Ireland will collect about you via the Community Finance Ireland website and loan applications. Data collected by UCIT or UCIT Ireland may be stored on Community Finance Ireland’s centralised database.
Your rights in relation to your personal data are set out in section 8, and you may submit any such request to either UCIT or UCIT Ireland directly. The entity that you submit the request to shall be responsible for dealing with the request and responding to you.