Privacy Notice
Data Protection Notice to Members (Effective from 25th May 2018, updated July 2025)
Members are encouraged to read this notice which sets out essential information about the
personal data we collect from you, how we use and safeguard this information, who we share it with
and why, and how long we will keep it on file. It also explains your rights, some of which are
new, arising from the General Data Protection Regulation (GDPR).
1. Who we are
Le Chéile Credit Union Limited was created through the merger of Athboy and Oldcastle Credit
Unions in July 2024. Both credit unions have been looking after the financial services needs of their
members since their foundation in 1969 and 1970 respectively.
Le Chéile Credit Union is a financial cooperative, democratically owned and controlled by our
members, and operated for the purposes of promoting thrift, providing credit and other financial
services to members, and providing educational services to members for the promotion of their
economic, social and cultural wellbeing. Personal data is processed for these purposes and no
others.
2. Our approach to Data Protection
We have always appreciated your trust in us to collect, process and protect your personal
information and we will continue to look after your information in a way that merits your trust. As a
data controller, we are committed to meeting our obligations under the GDPR and have appointed a
Data Protection Officer (DPO), who has oversight of our information practices and is responsible for
ensuring your rights are fulfilled. The DPO is also a point of contact for members should you have
any questions or concerns about your personal information.
In the context of the GDPR and the Data Protection Acts (1988 as amended), Le Chéile Credit Union
Ltd is the data controller1
You can contact our DPO at DPO@lecheilecu.ie or write to: Data Protection Officer, Le Chéile Credit
Union, Main St, Athboy, Co Meath, C15 D324 or Millbrook Road, Oldcastle, Co Meath.
3. The information we collect and hold about you
Depending on which of our savings, loans, transaction or other services you use, we will collect
different types of information from you or about you. Most of the information we collect is personal,
and some of it is very private to you, including information about your financial situation, person(s)
you have nominated on your account, and your state of health. Information about health is treated
as a “special category”, meaning that we apply additional stringent safeguards against its improper
collection, use or disclosure.
We collect and store only the information that we need to look after you as a member and this will
include:
Information we hold about you as a member
Your personal identification and descriptors
o Full name/maiden name/signature
o Current and previous addresses
o Email address; phone number(s) and other contact information
o Age/date of birth
o Gender
o Marital status
o Partner/spouse; number of dependents
o Names and addresses of person(s) nominated on your account
o Occupation and place of work
o Income
o Tax Identification Number/PPS Number
o Proof of identity and address e.g. copy of driving licence/passport and utility bills
o Accommodation status; mortgage or tenancy information
o IP address
o Biometric data including photographic ID, CCTV footage and voice (call)
recordings
o Your state of health and related information
o Your bank account or other credit union account details
o Payroll, credit or payment card details
4. How we collect this information
We record and file the identification and contact information and other data that you input into our
online or printed forms or provide to us over the phone or in person when you join the credit union.
We can only deal with and communicate with the member, so when you contact us we may need to
verify your identity, for example by asking you a security question or looking for some additional
detail about your account or dealings with us that only you would know.
When we need information about a nominated person(s) on your account we will obtain that
information from you, as the member.
We may record and/or make notes about phone conversations and will always tell you when we do
so.
Our website makes limited use of ‘cookie’ technology. A cookie is a piece of text that our server
places on your device when you visit our website. The type of cookie we use is “a non-persistent
session enabler” which means it is used only to allow your device to communicate with the site
while you log-in and use the site; the cookie expires when you log out of the site. We also collect the
IP address of any device which is trying to connect with the site and use this to track successful or
failed attempts at log-in to your account and the number of attempts made. You can find more
information on our Cookie Policy document on our website.
5. Information from other sources2:
Sometimes we collect information about you from other sources. Again, this can be dependent on
which of our services you are using. Some examples are below:
• If you apply for a loan, we may be required by law to consult credit rating agencies, such as
the Central Credit Register.
• When a member decides to complete a Form of Nomination3 on their account they will give
us personal data on the nominated person so we can contact them should it become
necessary.
• Should you decide to volunteer with us and apply for a position on our Board of Directs, we
are required to complete fitness and probity checks. This is required under regulation by the
Central Bank of Ireland
Other sources of publicly available information can also be consulted, such as:
• Registers of companies and company directors, such as the Companies Registration Office,
Solocheck, etc.
• the Register of Personal Insolvency Arrangements,
• the Bankruptcy Register
• the Register of Beneficial Ownership
Whatever the source, we collect and store only the information that we need to look after you as
a member.
6. The purposes for which we process your personal data4
We use information about you to:
• Set up and operate your credit union accounts on your behalf;
• Meet our obligations to you under the Credit Union’s Registered Rules;
• Provide savings, loan, transaction and other financial and educational services to you as a
member;
• Process your Life Saving, Loan Protection or Death Benefit Insurance claims and associated
payments;
• Keep our records up to date to contact you when required and provide the best customer
service;
• Respond to your requests and provide information;
• Address any complaint you may have about our services;
• Meet our legal obligations and respond to requests from the Central Bank, courts or
enforcement authorities;
• Produce internal management information to run our business and identify ways in which we
can improve our services;
• Provide relevant information to other financial service providers in the event of you requesting
this or when you transfer to another credit union; and;
• Perform any other financial services or co-operative activities which we are obliged to
undertake, or which we have gained your consent to perform
• Keep you informed about our products and services
7. Profiling
We sometimes use personal data we have about you to carry out profiling to better understand our
memberships’ needs and wants, to identify areas of opportunity within our common bond, and to
tailor our marketing efforts.
Profiling is a special form of processing involving anonymous (member names are not included)
analysis of our members database, or sections of the member database. It is usually done for
marketing purposes, to look for clusters of members with similar characteristics and behaviours. For
instance, looking at members who are borrowing from us, and looking for common characteristics
among them, like age, stage, geographical location. Then, non-borrowing members with those same
or similar characteristics are sent information about appropriate products and services.
You have the right to object to your personal data being included in profiling.
8. Our lawful basis for processing5
To process your information lawfully and fairly, we rely on one or more of the following lawful bases:
o The performance of a contract;
o Legal obligation;
o Our legitimate business interests;
o Your consent; and,
o Protecting the vital interests of you or others
Some examples for each lawful basis are given below. Please note that some information is
processed under more than one lawful basis:
| Lawful basis | Examples of what we use your information for |
| Performance of a contract – between you and us, or in order to take steps prior to entering into a contract between you and us | When you ask to join the Credit Union, we must assess your eligibility to do so, for instance, establishing that you are part of our common bond. When you sign the application form, this is a contract in which you are agreeing to comply with the rules of the credit union. Similarly, if you apply for a loan from us, we assess your creditworthiness using your income and outgoings to identify whether you can afford the loan for which you are applying. Once approved, the credit agreement is a contract in which sign your agreement with the repayment programme outlined. |
| Legal obligation - we must process this information to comply with our legal obligations. | We process your personal information to
|
Our legitimate interests - means the interests We will assess whether the legitimate interest
| We produce internal management information potentially useful services for you. We use this
|
| Your consent - we require your consent for processing certain information and will ensure this is obtained under the principles: • Free will - your consent must be freely given and not influenced by external factors • Specific - we will be clear on what exactly we are asking your consent for • Positive action - clear affirmative action is required. We will not use pre-ticked boxes, or imply or assume your consent • Recorded - we will keep a record of your consent and how and when obtained • Right to withdraw - you can withdraw your consent at any time; we will stop any processing that requires your consent once you request this; | With your consent, we will let you know about
|
| Protecting the vital interests of you or others | Sharing information to serve you
|
9. How we keep your information safe
The safety of your information and data is very important to us. We keep our computers, files and
buildings secure.
Transit of paper files is strictly limited. Where necessary to have member information available for
e.g. Board or Committee meetings, meeting rooms are secure, and no member information is left in
the open or on view to external parties.
Incoming post is brought directly to our office and opened by our staff. Outgoing post is either
collected from our office by An Post or brought to the Post Office by our staff.
Electronic copy files are stored on our proprietary IT system which requires user authentication to
access it. Back-ups of electronic files are stored securely off site. Laptops are encrypted at hard-drive
level. Use of memory sticks and other portable drives is limited, restricted to management
personnel, and all external drives are encrypted.
All files and hard drives being disposed of are shredded and this is certified by the shredding service
provider.
When you contact us by phone to ask about your information, we will ask you to verify your identity.
10. How long we keep your personal information for
To meet our legal and regulatory obligations, we hold your information while you are a member and
for a period of time after that. We do not hold it for longer than necessary. To help you understand
how long we hold your data for, we have summarised our internal retention schedules below.
Please note that these retention periods are subject to legal, regulatory and business requirements,
which may require us to hold the information for a longer period. For example, we must meet
minimum retention standards for taxation and audit requirements.
To meet such needs and to protect your interests as well as the credit union’s interests, we may
need to hold data for longer than our internal schedules dictate. However, we will not retain data
that is no longer needed, and we continuously assess and delete data to ensure it is not held for
longer than necessary.
| Document Type | Example Document | Retention Period |
| Account and service information | Membership account opening
| 7 years beyond account closure |
| Account operation records including instructions, communications and complaints • Bank details; IBAN • Transactions and receipts • Accounting records | 7 years beyond completion of the transaction or contract or resolution of the complaint concerned | |
Loan information • Supporting materials, such as | 7 years beyond the expiry of Deleted on expiry of the loan | |
| Revenue/Tax documentation | Income tax and DIRT records | 7 years beyond completion of the transaction concerned |
| Other records | • Records relating to legal claims • CCTV footage and voice recordings | 7 years beyond closure of the case One Month |
11. Your information and third parties
Sometimes we share your information with third parties, such as persons or companies with whom
we do business and who provide products or services e.g. IT Services that we use in conducting our
business, including managing our relationship with our members.
Similarly, we may share or disclose personal data to professional advisers, e.g. legal advisers,
accountants, auditors, whom we may engage for any reasonable purpose in connection with our
business, including assistance in protecting our rights.
We will only share or disclose the minimum information that they need in order to provide the product
or service and will expect those parties to ensure that the information is always adequately protected.
Before we make any transfer of personal data, we require these third parties to sign a contract with
us committing to the same levels of data protection that we have and guaranteeing that all necessary
safeguards and controls have been implemented to ensure there is no risk to your data rights and
freedoms.
Irish League of Credit Unions (ILCU) Affiliation: The ILCU (a trade and representative body for credit
unions in Ireland and Northern Ireland) provides professional and business support services such as
marketing and public affairs representation, monitoring, financial, compliance, risk, learning and
development, and insurance services to affiliated credit unions. As this credit union is affiliated to
the ILCU, the credit union must also operate in line with the ILCU Standard Rules (which members of
the credit union are bound to the credit union by) and the League Rules (which the credit union is
bound to the ILCU by). We may disclose information in your application or in respect of any account
or transaction of yours from the date of your original membership to authorised officers or
employees of the ILCU for the purpose of the ILCU providing these services to us.
The Privacy Notice of ILCU can be found at www.creditunion.ie
The ILCU Savings Protection Scheme (SPS): We may disclose information in any application from you
or in respect of any account or transaction of yours from the date of your original membership to
authorised officers or employees of the ILCU for the purpose of the ILCU providing these services
and fulfilling requirements under our affiliation to the ILCU, and the SPS.
Electronic Payments: For the processing of electronic payments services on your account (such as
credit transfers, standing orders and direct debits), the Credit Union has entered into a Services
Agreement for the provision of SEPA based payments with Payac Services CLG which is a credit union
owned CUSO and also through non participation agreements with Danske Bank as the STEP2 direct
participant partner bank. This provides an electronic payments service platform for the credit union
movement in Ireland. Payac Services CLG is an outsourced model engaging third party companies,
such as Danske Bank as a Partner Bank, to assist with the processing of payment data.
Details of your account transactions may also be shared with “NEXI” for the purposes of allowing
SEPA Instant Payments to be executed safely and keep antifraud measures up to date.
Insurance: As part of our affiliation with the ILCU, we purchase insurance from ECCU Assurance DAC
(ECCU), a life insurance company, wholly owned by the ILCU. To administer these insurances, we
may pass your information to ECCU and it may be necessary to process ‘special category’ personal
data about you. This includes information about your health which will be shared with ECCU for the
purposes of our life assurance policy to allow ECCU to deal with insurance underwriting,
administration and claims on our behalf.
We also have to share information with third parties to meet any applicable law, regulation or lawful
request including dealing with complaints. For example, we have a legal obligation under the “Return
of Payments (Banks, Building Societies, Credit Unions and Savings Banks) Regulations 2008” to report
details to the Revenue in respect of dividend or interest payments to members, which include PPSN
where held.
In all such cases, we will only disclose the minimum amount of information required to satisfy our
legal obligation.
12. International transfers of data
We do not transfer data outside the European Economic Area (EEA).
13. Your personal information rights
This section sets out your rights, when they apply and our responsibility to you. The exercise of your
rights might be subject to certain conditions and we might require further information from you
before we can respond to your request. You may exercise your rights by contacting our Data
Protection Officer at: dpo@lecheilecu.ie or write to: Data Protection Officer, Le Chéile Credit Union
Limited, Main St, Athboy, Co Meath, C15 D324 or Millbrook Road, Oldcastle, Co Meath.
Accessing your personal information
As a member, you can ask us for a copy of the personal information we hold and further details
about how we collect, share and use your personal information. You can request the following
information:
• the purposes of the processing;
• the categories of personal data concerned;
• the recipients or categories of recipient to whom the personal data have been or will be
disclosed, in particular recipients in third countries or international organisations;
• where possible, the envisaged period for which the personal data will be stored, or, if not
possible, the criteria used to determine that period;
• where the personal data are not collected from the data subject, any available information as to
their source;
• the existence of automated decision-making and meaningful information about the logic
involved, as well as the significance and the envisaged consequences of such processing for the
data subject.
• Any personal data we might transfer to an organisation outside of the area where the GDPR is in
effect, including any safeguards around such transfers
Updating and correcting your personal details
You can easily update your personal and contact information by contacting us by email or letter. You
may be asked to provide supporting documentation to support your request.
If you contact us over the phone to edit or delete any information on your behalf, we will ask you
questions in order to verify your identity.
Deleting your information (right to be forgotten)
You may ask us to delete your personal information or we may delete your personal information
under the following conditions:
• the personal data are no longer necessary in relation to the purposes for which they were
collected or otherwise processed;
• you withdraw your consent where there is no other legal ground for the processing;
• you withdraw your consent for direct marketing purposes;
• you withdraw your consent for processing a child’s data;
• you object to automated decision making;
• the personal data have been unlawfully processed;
• the personal data have to be erased for compliance with a legal obligation.
A request to delete your personal information cannot place this credit union in conflict with existing
legislation requiring the retention of the information.
Removing consent
Where we process your data solely on the basis of your consent, i.e. for direct marketing purposes or
to obtain feedback from you about our services, you are entitled to withdraw your consent to such
processing at any time. You can do this by contacting us by email or letter.
Ask us to suspend processing your personal data (Right to restriction) You may have the right to
restrict or object to us processing your personal information. We will require your consent to further
process this information once restricted. You can request restriction of processing where:
• The personal data is inaccurate, and you request restriction while we verify the accuracy;
• The processing of your personal data is unlawful;
• You oppose the erasure of the data, requesting restriction of processing instead;
• You require the data for the establishment, exercise or defence of legal claims but we no longer
require the data for processing;
• You disagree with the legitimate interest legal basis and processing is restricted until the
legitimate basis is verified.
Moving your information (your right to Portability)
Where possible we can share a digital copy of your information directly with you or another
organisation. We will provide this information in a structured, commonly used and machine
readable format. Note, we can only share this information where it has been processed
electronically (hard copy documents are excluded for portability) and was processed either under
your consent or under the lawful basis of provision of a credit union service. In line with GDPR
guidance, information that is processed to satisfy a legal obligation or that we process as part of our
legitimate business interests, will not be regarded as portable (see section 7: ‘The purposes for
which we process your personal data’).
Ask us to stop processing your personal data (Right to object)
Where we are sending you direct marketing materials and newsletters, or we are using your personal
data for profiling purposes for direct marketing, you can ask us to stop doing so.
Automated decision-making
We can occasionally use automated decision-making tools to assist us in making decisions, for
instance, in assessing loan applications. We do not depend on such tools as the sole basis for making
our decisions. Should it ever be the case that we use only automated decision-making, and you are
unhappy with the resulting decision, you have the right to obtain human intervention on this, to
express your point of view on the decision, and to contest or appeal that decision.
Restrictions and charges
You should note that the exercise of your rights might be subject to certain conditions or restrictions.
Where this happens, we will let you know.
Additionally, your right to obtain information cannot adversely affect the rights and freedoms of
others. Therefore, we cannot provide information on other people unless legally obliged to do so.
Usually, there is no charge when you contact us to ask about your information. If requests are
deemed excessive or manifestly unfounded or unreasonable, we may charge a reasonable fee to
cover the additional administrative costs, or we may choose to refuse the requests.
14. Making a complaint
If you have a complaint about how we are using your personal information, please let us know, so
that we have the opportunity to put things right as quickly as possible. If you wish to make a
complaint you may do so in person, by phone, by letter or by email. Please be assured that all
complaints received will be fully investigated. You can register a complaint through our DPO and we
ask that you provide as much information as possible to help us resolve your complaint quickly.
You can also complain directly to the Data Protection Commission, and their contact information is:
• Email: info@dataprotection.ie
• Phone: +353 (0)1 765 0100, or 1800 437 437
• Write to: Data Protection Commission, 6 Pembroke Row, Dublin 2, D02 X963
15. Updates to this notice
We will make changes to this notice from time to time, particularly when we change how we use
your information, such as in response to changing legal, technical or business developments. When
we update it, we will take appropriate measures to inform you, consistent with the significance of
the changes we make. You always will find an up-to-date version of this notice on our website at
www.lecheilecu.ie or you can ask us for a copy.
1 GDPR, Article 13 (1)(a)
2 GDPR, Article 14 (1)(c)
3 Under our Rules (Rule 23), by filling in a form of nomination, our members can nominate their property to a
person (or persons). This means that, should the member die, on the credit union receiving satisfactory proof
of the death of a member, payment of the nominated property is made to the nominated person(s).
4 GDPR, Article 13 (1)(c)
5 GDPR, Article 14 (1)(c)
6 GDPR, Article 13 (1)(d)
Download our Data Protection Privacy Notice
Le Chéile Credit Union Limited is regulated by the Central Bank
