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Legal Information

Common Bond Summary

You can apply for membership if you live or work in the below post code areas:

FY1 - FY8

PR1 - PR9

PR25, PR26

LA1 - LA4

Read more about the full CLEVR Money Common Bond.

Membership Terms and Conditions

T&C: Membeship
Membership
T&C: Savigs
Savings
T&C: Withdrawls
Withdrawals
T&C: Charges
Charges
T&C: Accessin Account Info
Accessing Account Information
Dividends
T&C: Dividends
Miscellaneous
T&C: Miscellaneous
Christmas Saver Account
T&C: Christmas Save Accont
Borrowing from CLEVR
T&C: Borrowing from CLEVR Money
Interest Charges
Defaults
T&C: Interest Charges

This document contains important information about your membership of CLEVR Money (CLEVR) and explains our joint obligations.

These terms and conditions relate to the operation of any accounts that you may hold with us. Any additional terms and conditions which are specific to a particular account or facility will be provided to you on application for a particular account or facility.

Any reference to shares refers to the deposits you hold with CLEVR.

“Working days” means Monday to Friday with the exception of public holidays.

These terms and conditions are also governed by English law and we are required by law to inform you that any agreements you enter into with CLEVR will be written in English and all our further communications with you will also be communicated to you in English.

  1. Membership of CLEVR is open to anyone covered by the common bond stated in the Rules of the Credit Union available on our web site or from the office on request.

  2. To become a full member you must be 18 years of age or over. Separate terms & conditions are available for Junior Savers accounts.

  3. On applying for membership we will need proof of your identity and evidence of your current address. We will provide this evidence by checking your identity electronically. A report will be produced and retained on file in order to comply with the Money Laundering Regulations 2007 and the Proceeds of Crime Act 2002.

  4. You must supply us with a beneficiary nominee to whom will be paid any funds held in your CLEVR accounts in the event of your death.

  5. We have the right to decline your application to open an account with us.

  6. A minimum of £5 must be maintained in your membership account at all times.

  7. Savings into your membership accounts may be made by payroll deductions, cheque, debit card, direct debit, standing order, bank transfer, direct benefits payment.

  8. Cheques must be made payable to CLEVR and have your membership number on the reverse.

  9. Savings made by direct debit may take between 3/5 working days to reach the Credit Union and be credited to your account.

  10. Cheques credited to a members account may take up to 10 working days before funds are cleared and you are able to draw down money deposited in this way.

  11. Savings through payroll deductions will be credited to your account on the date that the funds are received from your employer.

  12. You can change your regular savings amount by emailing or calling the office.

  13. Withdrawals from your share accounts will usually be made by BACS transfer to a nominated bank account or pre-pay debit card.

  14. There is no maximum withdrawal from cleared funds within your membership account.

  15. All withdrawals must be authorised by your signature on a completed withdrawal slip or by logging in to our secure online members’ area.

  16. You must keep your online login details secure. No responsibility will be accepted for any withdrawals made from an account where the correct PIN and passwords have been used.

  17. It is your responsibility to ensure that CLEVR have your correct bank account details. We accept no responsibility for funds paid out in cases where you have provided us with incorrect bank details.

  18. Withdrawals will usually be by BACS and settle in your nominated account within 3 working days of receipt of an instruction.

  19. Loans will be issued only after receipt of a signed Loan Agreement.

  20. All withdrawals are subject to the availability of funds in your membership account. A minimum balance of £5 is required at all times and where a member has a loan the minimum balance is one loan payment plus £5.

  21. You are able to nominate different bank accounts in which to receive electronic withdrawals by providing CLEVR with the bank name, branch, sort code, account number and the name of the account holder.

  22. You cannot normally cancel a withdrawal after we have processed your instruction. You will be liable for any charges incurred by CLEVR in attempting to cancel an instruction made by you.

  23. CLEVR reserves the right to stop any withdrawals on your Membership account in the event of you having an outstanding loan balance with CLEVR.

  24. CLEVR reserves the right to require a maximum of 60 days notice of withdrawal.

  25. If you make a deposit by cheque that fails to clear into our account, you will be liable for charges incurred by us. Such charges will ordinarily be deducted from your membership account.

  26. Such charges will be the same as those imposed on CLEVR by our bank.

  27. You will be liable for all charges incurred by CLEVR in recovering any debt owed by you to the credit union that has fallen into default.

  28. You will receive a Statement of Account for CLEVR at least annually showing you all transactions on your share accounts and any loan account that you have with CLEVR.

  29. You are able to check your account balances at any time by registering on the members’ area of our web site.

  30. You should notify us as soon as possible if you believe that your statement or account balance includes something you believe to be incorrect or not made in accordance with your instructions.

  31. We will rectify any incorrect entries on your account as soon as possible.

  32. Before providing you with any information about your account over the telephone, all staff at CLEVR will follow our standard security procedures in order that we are satisfied about your identity.

  33. These procedures will include such steps as verifying your full name, address, date of birth and account password.

  34. We may not be able to assist you if we decide that we are unable to identify you using our security procedures. This is for your own protection.

  35. Any dividend shall be declared on all full shares held during the preceding financial year. New members joining CLEVR will be entitled to a proportional part of the dividend on any shares held for less than the full year on every full month of membership.

  36. CLEVR’s financial year runs from 1st of October until the 30th of September.

  37. Dividends shall be paid to those in membership of CLEVR the first working day after the dividend is declared.

  38. The Board of Directors reserves the right not to pay a dividend in accordance with the Rules.

  39. Dividends will be credited to your accounts gross, that is without deduction of tax. It is your responsibility to notify the Inland Revenue of any such receipt.

  40. We may use any contact details you provide to us for service related reasons.

  41. It is your responsibility to notify CLEVR of any changes to your contact details. If you do not notify us promptly of any changes to your details, the security of your personal information could be put at risk.

  42. You may make transfers between certain CLEVR accounts. Such transfers will normally be dealt with on the day we receive your instruction.

  43. If there has been no activity on your account in a twelve month period, we may make your membership dormant. You will be contacted prior to us taking this action and given the option of reactivating or closing your account.

  44. The maximum amount that you can save in your CLEVR accounts is £10,000 or another amount set from time to time by the board of directors. The latest amount can be supplied by office staff on request.

  45. These terms & conditions may be varied from time to time and an up to date copy will always be available on our website or from the office on request.

  46. All members have a 14 day cooling off period on all of our financial goods and services. If you change your mind about any of our financial goods and services and decide not to proceed, you need to notify us in writing of your decision.

  47. A member of CLEVR can open up a Christmas Saver Account with CLEVR at any time by completing the relevant application form.

  48. To apply for a Christmas Saver Account, an individual must have a standard membership account with CLEVR.

  49. Withdrawals from the Christmas Account can be made between the first working day in November and the last working day before Christmas using the usual withdrawal methods.

  50. You must be 18 or over to borrow from CLEVR

  51. The maximum loan available from CLEVR is £15,000 but we reserve the right to change this figure at our discretion. You should check the maximum amount available before making a loan application.

  52. The maximum repayment period for CLEVR loans is five years. The actual maximum repayment period will vary according to the type and size of loan that you apply for.

  53. CLEVR will conduct a Credit Reference Agency (CRA) search in connection with your loan application. The CRA will record details of the application on your credit report. This will form part of your credit history whether or not you proceed and if you make several applications for credit within a short period of time, this may temporarily affect your ability to obtain credit.

  54. Before you can end your membership of CLEVR all outstanding loans must be paid off in full.

  55. Rates for different products and different values of loan may vary. Interest is charged daily on a reducing balance basis. Latest interest rates are available on our web site.

  56. If a loan account falls into arrears, no withdrawals will be allowed from the account until the account is up to date. We reserve the right to offset any share balance against an unpaid loan.

  57. We will share details of how you manage your loans with Credit Reference Agencies (CRA). If you fail to respond to default notices sent by CLEVR, we will register the default with the CRAs. The registration of a default notice may affect your ability to obtain further credit.

  58. CLEVR will take all necessary steps, including passing your debt to a debt collection company or take legal action to recover loans in default.

T&C: Defaults
About Us

CLEVR & CLEVR Money are trading names of Blackpool Fylde & Wyre Credit Union Limited, authorised and registered by the Financial Conduct Authority (FCA) with the Firm Reference Number 478917. Our members’ savings are protected under the terms and conditions of the Financial Services Compensation Scheme (FSCS). This guarantees 100% of the first £85,000 you have saved. Our registered address is 13 Birley Street, Blackpool FY1 1EG.

Complaints

We aim to provide our members with a first class service, however we appreciate that mistakes can happen and we therefore welcome the opportunity to put things right. We will investigate your concerns as quickly as possible and take steps to rectify the situation and where appropriate, prevent a recurrence. Please contact the Complaints Officer in the first instance to address any of your concerns. If however you remain dissatisfied, a full copy of our complaints policy and procedure is available on request from our office. You may also be able to refer your complaint to the Financial Ombudsman Service (FOS) once CLEVR has had the opportunity to respond to your complaint.

Data Protection

CLEVR will process your data in accordance with your rights under the Data Protection Act 2018 and the General Data Protection Regulation. Your information may be processed by CLEVR in any form and on any database by us for the following purposes:

* To consider any applications made by you.

* To help us to make credit decisions about you.

* To deal with your accounts or run any other services we provide to you.

* To undertake statistical analysis; financial risk assessment, money laundering checks (which may include telephoning you), compliance and regulatory reporting, fraud prevention and debt tracing and collection.

* To help us identify products and services that may be of interest to you. You may tell us at any time if you do not wish to receive marketing communications from us by writing to us providing your full name, address and account details.

Sharing Information

We take the security and confidentiality of your personal data seriously. We will only share your data with

* Our agents or subcontractors for operational reasons.

* Any persons including but not limited to, insurers, who provide a service or benefits to you or for us in connection with your accounts.

* Licensed Credit Reference Agencies, fraud prevention and other agencies to help prevent crime or where we suspect fraud.

* For the purpose of compliance with regulatory requirements.

* Where required by law.

CLEVR & CLEVR Money are trading names of Blackpool Fylde & Wyre Credit Union Limited, authorised and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Firm Reference No: 478917. Co-operative No: 742C. Registered office: 13 Birley Street, Blackpool FY1 1EG

Complaints

How to Make a Complaint

We aim to offer our members a high quality of service at all times. If you feel you have been let down, or you are unhappy with the service you have received please tell us about it, and we will do our best to put things right.

We will provide you with a copy of our internal complaints procedure on request.

You can make your complaint known to us in a number of ways:

  • By phone – 01253 478 827

  • By Email – hello@clevr.money

  • In Writing to - 13 Birley Street, Blackpool, Lancashire, FY1 1EG

 

What we will do

We want to resolve your issues as quickly as possible, however, more complex problems may involve conducting an investigation.
We will review your complaint in a fair, impartial and timely manner.

Within 3 working days from the date your complaint was received

If your complaint has not been satisfactorily resolved, you will receive a written letter from us confirming that your complaint is being looked into.

Within 8 weeks from the date your complaint was received

All our complaints should be resolved within 8 weeks and you will receive a copy of the resolution in writing for your records.

If this is not possible within 8 weeks, we will write to you to let you know why we have not resolved your issues and when we expect to issue you with a final response.


Your rights – Financial Ombudsman Service (FOS)

If you are unhappy with the resolution we offer, or we have not provided a resolution within 8 weeks from the date we received your complaint, you can escalate your complaint to FOS.

FOS is an impartial organisation who mediates on complaints between companies and their customers. Their contact details and guidance for complaints are below:

 

Website
http://www.financial-ombudsman.org.uk/consumer/complaints.htm

Telephone Number
0300 123 9123 or 0800 023 4567

 

Fax Number
0207 964 1001

 

Postal Address
Financial Ombudsman Service
Exchange Tower
London
E14 9SR

Please note – If you wish to escalate your complaint to FOS, please try and do so within 6 months of the date on your Final Response or 8 week letter, as they can reject any complaints they receive after this time.

Privacy Policy

We are committed to protecting our members’ privacy. The credit union requires any information marked as mandatory for membership to either meet legal obligations or to enable us to perform our contract with you. Where you are not able to provide us with this information, we may not be able to open an account for you. Where we request further information about you not required for these reasons, we will ask you for your consent.

How we use your personal information

Blackpool Fylde & Wyre Credit Union Limited may process, transfer and/or share personal information in the following ways:

For legal reasons

  • confirm your identity

  • perform activity for the prevention of financial crime

  • carry out internal and external auditing

  • record information about you on a members’ register

 

For performance of our contract with you

  • deal with your account(s) or run any other services we provide to you;

  • consider any applications made by you;

  • carry out credit checks and to obtain and provide credit references

  • undertake statistical analysis, to help evaluate the future needs of our members and to help manage our business

  • To send you statements, new terms & conditions (including changes to this privacy statement), information about changes to the way your account(s) operate and notifications of our general meetings.

 

For our legitimate interests

  • recover any debts owed to us

 

With your consent

  • maintain our relationship with you including marketing and market research through the use of Zoho Marketing Plus

 

Sharing your personal information

We will disclose information outside the credit union:

  • to third parties to help us confirm your identity to comply with money laundering legislation

  • to credit reference agencies and debt recovery agents who may check the information against other databases – private and public – to which they have access to

  • to any authorities if compelled to do so by law (e.g. to HM Revenue & Customs to fulfil tax compliance obligations)

  • to fraud prevention agencies to help prevent crime or where we suspect fraud;

  • to any persons, including, but not limited to, insurers, who provide a service or benefits to you or for us in connection with your account(s)

  • to other members if they request to view the members’ register which contains certain limited information i.e. names, joining dates, leaving dates, and mailing addresses

  • to our suppliers in order for them to provide services to us and/or to you on our behalf

  • to anyone in connection with a reorganisation or merger of the credit union’s business

  • other parties for marketing purposes

  • for marketing purposes we will share information with Zoho Marketing Plus to enable us to deliver our digital marketing which includes but is not limited to marketing emails, newsletter distribution and customer surveys

Sharing your personal information for marketing purposes

 

We use the service Zoho Marketing Plus to deliver our digital marketing which includes:

  • Marketing emails

  • Newsletter distribution.

  • Management of Corporate Social Media Accounts

  • Customer Surveys

  • Management of Webinars and Events for customers and stakeholders

  • Website performance via use of Cookies

  • Collateral Content Management

The lawful basis for CLEVR Money to collect and use your personal information is because:

  • You have given us clear consent

Any marketing activities will be in compliance with the Privacy & Electronic Communications Regulations (PECR). A clear opt-in model will be used with a clear and easy process for you to opt out of marketing, if you so wish.

For further information regarding the Zoho Group can be found here - https://www.zoho.com/en-uk/privacy.html

Where we send your information

While countries in the European Economic Area all ensure rigorous data protection laws, there are parts of the world that may not be quite so rigorous and do not provide the same quality of legal protection and rights when it comes to your personal information.

The credit union does not directly send information to any country outside of the European Economic Area, however, any party receiving personal data may also process, transfer and share it for the purposes set out above and in limited circumstances this may involve sending your information to countries where data protection laws do not provide the same level of data protection as the UK.

Retaining your information

The credit union will need to hold your information for various lengths of time depending on what we use your data for. In many cases we will hold this information for a period of time after you have left the credit union. Details are available upon request.

Credit rating agencies

In order to process credit applications you make we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.

We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates. This may affect your ability to get credit.

The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail on:

 

Your Rights

Your rights under data protection regulations are:

  • The right to be informed

  • The right to access

  • The right of rectification

  • The right to erasure

  • The right to restrict processing

  • The right to data portability

  • The right to object to data processing

  • Rights related to automating decision-making and profiling

  • Right to withdraw consent

  • The right to complain to the Information Commissioner’s Office

 

Please see our website here for more information

Security

We take the protection of your information very seriously and high security measures will be taken to ensure your data is protected. All online banking activity is protected by a secure certificate using the TLS1.2 standard encryption which provides an industry standard level of security.

 

Cookies

To provide you with a good online journey, we will store a number of cookies on your machine, to help us associate important information with you.

For more information on cookies, please view our cookie policy.

 

External links

You may encounter links to external websites when using our website, this policy does not cover these websites and we encourage you to view each website’s privacy policy before submitting any information.

To speed up the process of assessing the affordability of a loan, we do encourage you to sign up to the Perfect Data Solutions website. This allows us to access your finance and transactional data for the purpose of income and expenditure assessment.  Participation is consent based and not mandatory. You can still use the alternative method of manually sending us bank statements.

Contact us

If you want more information on how we use and hold your data, or if you think we may be holding incorrect information, please get in touch on the details below and we will happily review the information we store. We will keep all the records we have on you unless you tell us otherwise.

If you would like to request a copy of all the personal details we are holding on you then please get in touch on the details below. Any request will be subject to a £10 administration fee.

If you no longer wish us to hold your personal data, please contact us on the details below. Please note that we may not be able to provide you with our services without access to your data.

  • In person at– 13 Birley Street, Blackpool, Lancashire, FY1 1EG

  • By email to– hello@clevr.money

  • By telephone on– 01253 478 827

  • In writing to– 13 Birley Street, Blackpool, Lancashire, FY1 1EG

 

Data Protection Policy

Introduction (DPP)
Data Protection Policy

  1. Introduction

  2. Definitions

  3. GDPR Principles

  4. Lawful Bases for Processing

  5. Accountability and Governance

  6. Individual Rights

  7. Data Security

  8. Personal Data Breaches

  9. Data Retention

  10. Data Accuracy and Limitation

  11. Data Disclosures

  12. Complaints

 

 
1. Introduction

 

CLEVR Money collects, holds and processes personal data about customers, employees and other key stakeholders. It therefore has a number of legal obligations under the General Data Protection Regulation (GDPR) and the provisions of the Data Protection Act 2018 (DPA 2018).

 

Within this policy we will set out how CLEVR Money will comply with data protection law, protect personal data and process data in a transparent manner. The policy ensures that employees, board members, suppliers and all third parties working on behalf of CLEVR Money, understand their responsibilities. The policy applies to all personal data, regardless of whether it is held in a paper or electronic format.

 

2. Definitions

CLEVR Money is defined as a data controller as it ‘determines the purpose and means of processing of personal data’ and as such it pays an annual fee to the Information Commissioner’s Office as required by the Data Protection (Charges and Information) Regulations 2018.

The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified. This definition provides for a wide range of personal identifiers to constitute personal data, including name, DOB, postal address, email address, images, bank details or online identifiers.

The GDPR refers to sensitive personal data as ‘special categories of personal data’ and the GDPR says it is more sensitive, and so needs more protection. For example, information about an individual’s race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, sex life or sexual orientation, are all ‘special categories of personal data’.

 

3. GDPR Principles

Article 5(1) of the GDPR contains principles relating to the processing of personal data and CLEVR Money is committed to complying in full with these principles. Article 5(1) states personal data shall be:

  1. a) processed lawfully, fairly and in a transparent manner

  2. b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes

  3. c) adequate, relevant and limited to what is necessary

  4. d) accurate and, where necessary, kept up to date

  5. e) kept in a form which permits identification of data subjects for no longer than is necessary

  6. f) processed in a manner that ensures appropriate security of the personal data

 

Article 5(2) also requires that:

“the controller shall be responsible for, and be able to demonstrate, compliance with the principles.”

4. Lawful Bases for Processing

CLEVR Money will only process personal data if one of the following Article (6)(1)  lawful bases apply:

(a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes;

(b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

(c) processing is necessary for compliance with a legal obligation to which the controller is subject;

(f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party

CLEVR Money will only collect and process ‘special categories of personal data’ if one of the additional conditions set out in Article 9(2) has been satisfied.

 

5. Accountability and Governance

 

Data Protection Lead

CLEVR Money Data Protection Lead is the first point of contact for any data protection queries and their contact details are as follows:

Data Protection Lead (Governance & Administration Manager)

CLEVR Money, 13 Birley Street, Blackpool, FY1 1EG

or email governance@clevr.money

 

Data Protection Officer (DPO)

Under the GDPR it is mandatory for companies who carry out certain types of processing activities to designate a DPO. The DPO’s minimum tasks are defined in Article 39:

  • inform and advise the organisation and its employees about their obligations to comply with the GDPR and other data protection laws

  • monitor compliance with the GDPR and other data protection laws, including managing internal data protection activities, advise on data protection impact assessments, train staff and conduct internal audits

  • first point of contact for the Information Commissioners Office

 

The contact details for CLEVR Money designated DPO are as follows:

Data Protection Officer

Blackpool Council, PO Box 4, Blackpool, FY1 1NA

or email dataprotectionofficer@blackpool.gov.uk

 

Register of Processing Activities (RoPA)

CLEVR Money is required to maintain records of activities related to higher risk processing of personal data and CLEVR Money therefore commits to maintaining an up to date RoPA. All employees are required to notify the Data Protection Lead of any new processing activities or changes to existing processing activities to assist with the maintenance of this register. The RoPA will be made available to the supervisory authority on request.

 

Workforce Training

CLEVR Money is committed to providing appropriate data protection training to its workforce as part of their induction process and will issue regular refresh training throughout the course of their employment or in the event of any changes in data protection law. CLEVR Money will retain a record of this training programme and this will be made available to the supervisory authority on request.

 

Data Protection Impact Assessments (DPIA’s)

Data Protection Impact Assessments (DPIAs) are a tool which enable organisations to identify the most effective way to comply with their data protection obligations and meet individuals’ expectations of privacy. CLEVR Money commits to completing DPIA’s for certain listed types of processing, or any other processing that is likely to result in a high risk to individuals’ interests. Employees must consult the Data Protection Lead to see if they need to complete a DPIA before they embark on any new processing activities or make changes to existing processing activities. For further information employees should consult CLEVR Money’s ‘Data Protection Impact Assessment (DPIA) Procedure’.

 

6. Individual Rights

 

Right to be informed

Individuals have the right to be informed about the collection and use of their personal data. This is a key transparency requirement under the GDPR. We call this ‘privacy information’ and CLEVR Money publishes its customer privacy notice at Privacy Notice.

 

Right of Access

Individuals have the right to access their personal data (commonly known as ‘subject access’) and supplementary information about the processing of their data. The right of access allows individuals to be aware of and verify the lawfulness of the processing of their personal data. The information that can be requested includes:

 

  • confirmation that their personal data is being processed

  • access to a copy of the data

  • the purposes of the data processing

  • the categories of personal data concerned

  • who the data has been, or will be, shared with

  • how long the data will be stored for

  • the source of the data, if not the individual

  • whether any automated decision-making is being applied to their data, and what the significance and consequences of this might be for the individual

 

‘Subject access’ requests should be directed to the Data Protection Lead. A response will be issued without delay and at the latest within one month of receipt of the request. Please note CLEVR Money will take reasonable steps to verify the identification of the applicant. For further information employees should consult CLEVR Money’s ‘Subject Access Procedure’.

 

Individual Rights

GDPR also empowers individuals with the right to rectification, erasure, right to restrict processing, data portability, right to object and rights in relation to automated decision making or profiling. CLEVR Money will carefully consider any requests under these rights and requests can be submitted to the Data Protection Lead who will consult with the DPO.

 

7. Data Security

Principle f) states data should be processed in a manner that ensures appropriate security of personal data. This means CLEVR Money must have appropriate security to prevent the personal data it holds being accidentally or deliberately compromised. Particular attention will be paid to the need for the security of any ‘special categories of data’.

 

All employees who process electronic data will comply with CLEVR Money’s ‘Information and ICT Security Acceptable Use Policy’.

 When holding or processing electronic data employees must ensure:

  • passwords meet appropriate security standards, be changed at regular intervals and must not be divulged to any other persons

  • ensure corporate portable devices, such as laptops, USB’S and hard drives that contain personal data are stored in a locked cupboard or draw when not in use

  • where personal data is shared with a third party, employees should carry out due diligence and ensure the data is sent in a secure manner or appropriate measures are taken to mitigate the risk of individuals being identified

  • when sending personal data to a third party, staff must carefully check the recipient and their contact details

  • where personal devices are used to access corporate email accounts, staff should ensure appropriate passwords are applied to the device

  • employees should not open links when emails are received from unknown recipients or the emails appear suspicious

  • personal data must be stored in a secure and safe manner, with careful consideration made to who can access the data

  • when working with personal data, employees should ensure the screens of their computers are always locked when left unattended

  • employees should not save copies of personal data to their own devices, they should always access and update the central copy of any data

  • employees must adopt a clear desk culture

 

Manual data will be stored where it is not accessible to anyone who does not have a legitimate reason to view or process that data. Employees should carefully consider whether they need to take any manual data offsite before doing so and record instances where any ‘special categories of data’ is taken offsite.

8. Personal Data Breaches

A personal data breach is “a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed in connection with the provision of a public electronic communications service”.

 

A personal data breach most commonly means that someone other than the data controller gets unauthorised access to personal data, but it can also include where personal data is accidentally altered or deleted. Common examples of data breaches include the loss or theft of equipment, the loss of hard copies of personal data and data being sent to the wrong recipient by either post or email.

 

The GDPR introduces a duty on all organisations to report certain types of personal data breach to the relevant supervisory authority, where feasible, CLEVR Money must do this within 72 hours of becoming aware of the breach. It is therefore essential that all employees follow the CLEVR Money’s ‘Personal Data Breach Procedure’ and make the Data Protection Lead aware of any incidents without undue delay. If the Data Protection Lead is unavailable it should be brought to the attention of the relevant manager.

 

The Data Protection Lead and DPO will to investigate all incidents to establish whether or not a personal data breach has occurred. If a personal data breach is confirmed, the DPO will carefully consider whether it is required to notify the Information Commissioner and the data subjects affected.

 

9. Data Retention

Principle e) states data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed. Data will only be retained for the specified period outlined in the records management schedule that CLEVR Money has adopted and will be destroyed in a secure manner thereafter. A copy of the records management schedule is available in CLEVR Money’s ‘Records Management Policy’.

10. Data Accuracy and Limitation

CLEVR Money is required to take reasonable steps to ensure data is kept accurate and up to date. It is the responsibility of all employees who work with data to take reasonable steps to ensure it is kept as accurate and up to date as possible. Employees must ensure:

 

  • data will be held in as few places as necessary and employees should avoid creating any unnecessary additional data sets

  • employees should take every opportunity to ensure data is updated

  • CLEVR Money will make it easy for data subjects to update the information it holds about them

  • data should be updated as soon as any inaccuracies are discovered

 

CLEVR Money will only collect personal data for specified, explicit and legitimate reasons which are outlined in the privacy notice. If we wish to use personal data for reasons other than those given when we obtained it, we will inform the individuals concerned before we do so, and seek consent where necessary (unless an exemption applies).

11. Data Disclosures

In certain circumstances, the GDPR and Data Protection Act 2018 set out exemptions from some of the rights and obligations e.g. crime & taxation. Any requests for personal data under the exemptions must be made to the Data Protection Lead and will be carefully considered on a case by case basis by the DPO. Please note CLEVR Money will take reasonable steps to verify the identification of the applicant and will ensure an appropriate audit trail of the disclosure.

 

12. Complaints

If an individual is unhappy with the way in which CLEVR Money is handling their personal data or information, or is unhappy with the company’s response to a ‘Subject Access Request’, they can submit a complaint to the DPO. The DPO will carefully consider each complaint on a case by case basis and submit a response without undue delay.

 

If the complainant is not content with the outcome of their complaint, they may apply directly to the Information Commissioner’s Office. However, the ICO encourage you where possible to exhausts the organisation’s complaints procedure. Details on how to submit a complaint to the ICO are available at https://ico.org.uk/make-a-complaint/.

Open Banking

This section of our Privacy Policy relates to Open Banking and should be read in conjunction with the other clauses in our Privacy Policy.  In the event of conflict with any other clauses, this clause shall prevail.

 

What is Open Banking?

Open Banking is the secure way of providing access to your bank or building society account to providers who are registered for this purpose.

Registered providers and participating banks and building societies are listed under the Open Banking Directory.

Open Banking was set up by the UK Government to encourage more competition and innovation in the financial services sector.

As a forward thinking lender, we support the use of Open Banking as it allows us to process loan applications efficiently, securely and in our consumer’s best interests.

By permitting access to your bank or building society account information we are able to make a better lending decision as we shall be able to verify your income, outgoings and other matters in order to assess what loan terms would be suitable for you based upon what you can reasonably afford to repay.

Further information about Open Banking is available from www.openbanking.org.uk

 

Perfect Data Solutions:

How will my personal data be shared and used for the purposes of Open Banking?

By proceeding with your loan application via our website you expressly consent to us sharing your personal, contact and loan application details (“the Shared Personal Data”) with our registered Open Banking partner, Perfect Data Solutions Limited (“PDS”) who are also a credit reference agency.  During your loan application we shall safely and securely direct you to PDS’s secure portal (“the Portal”) for the purposes of granting PDS access to your bank or building society account information (“Transaction Information”). As soon as your Transaction Information is received it shall be reported back to us in the form of a completed search in order that we may continue to process your loan application (“the Permitted Purpose”).

Further information about PDS including their registered provider and regulatory status is available from www.lendingmetrics.com

 

Is Open Banking secure?

PDS are registered under the Open Banking Directory as an account information service provider and are also regulated by the Financial Conduct Authority as a payment services firm under number 802599.  Any data you submit via the Portal will be encrypted and its usage tracked as part of set Open Banking data security standards.

We are responsible for the secure transmission of any Shared Personal Data to PDS, for safely directing you to the Portal and for the safe receipt and usage of your Transaction Information.

You will not be required to share your banking password or log in details with either us or PDS.  Once you have given your explicit consent to share your bank account information on the Portal you will be directed to your own bank or building society’s login page where you will enter in your own login details directly.

Save as set out above or elsewhere in this Privacy Policy, we are not responsible for your direct data transmissions with PDS or with your own bank or building society.

 

How will my Shared Personal Data and Transaction Information be used?

PDS shall, subject to their own terms and conditions and privacy policy, and, if your bank or building society is registered to provide access under the Open Banking Directory, obtain your Transaction Information and submit this back to us for the Permitted Purpose. By way of example, the Transaction Information that we shall receive is likely to include information relating to your income, outgoings and credit worthiness.

PDS shall be entitled to re-access your Transaction Information for up to 90 days from the date of your original search result in order to refresh the search results, obtain a snapshot of your data or gather additional data.

PDS shall hold the Shared Personal Data and the Transaction Information they receive and retain according to their own terms and conditions and privacy policy, available on the Portal, which you will be required to read and consent to once directed their via our website.

As PDS are also a credit reference agency they may also share and keep a record of your Shared Personal Data and Transaction Information.

 

Will you use my Transaction Information data for any other purpose?

The Transaction Information we receive about you will only be used for the Permitted Purpose.  We do not sell or share Transaction Information with any third party.

Save as set out above the information contained in the rest of this Privacy Policy deals with how we collate, use, transfer, store, delete and other terms applicable to your personal data including Shared Personal Data and Transaction Information.

 

Do I have to provide you with my consent to proceed?

We will only request consent to view your Transaction Data where it is necessary for verifying your income and expenditure and determining your eligibility for a loan with us. You are under no obligation to provide us with consent via Open Banking, but we will still require sight of your Transaction Data through other means (e.g. PDF downloads of your statements from your bank or printed paper statements) which will be stored, used and processed in accordance with this policy. Failure to provide the requested information will lead to your loan being refused.

Where your bank or building society have already permitted access to your Transaction Information you shall need to contact them directly in order to withdraw your consent under their particular Open Banking terms and conditions.

 

Are any of my other rights under this Privacy Policy affected?

Your individual data protection and privacy rights including the right to access, correct, delete, object, restrict, withdraw consent, request transfer and/or make a complaint, continue to apply to relevant personal data we control or process and are dealt with elsewhere in this Privacy Policy.

Under Open Banking as your personal data is shared by your bank or building society and accessed by PDS you may also be able to exercise your individual data protection and privacy rights against either of them pursuant to their own terms and conditions and privacy policies.

 

Credit Kudos

How will my personal data be shared and used for the purposes of Open Banking?

By proceeding with your loan application via our website you expressly consent to us sharing your personal, contact and loan application details (“the Shared Personal Data”) with our registered Open Banking partner, Credit Kudos Limited who are also a credit reference agency.  During your loan application we shall safely and securely direct you to Credit Kudo’s secure website for the purposes of granting Credit Kudos access to your bank or building society account information (“Transaction Information”). As soon as your Transaction Information is received it shall be aggregated with any other transaction information that you have provided Credit Kudos with consent to access and automatically analysed using machine learning detection and prediction models to provide us with a comprehensive view of your financial behaviour, including predicted and historic spend analysis, key merchants, balances, recurring expenditure, credit behaviour, stopped payments, and risk indicators including recent loan commitments, liquidity, stopped payments, returned direct debits, unarranged overdraft usage, and gambling. This information will be reported back to us in the form of a completed search in order that we may continue to process your loan application (“the Permitted Purpose”).

 

Further information about Credit Kudos including their registered provider and regulatory status is available from https://www.creditkudos.com/

 

Is Open Banking secure with Credit Kudos?

Credit Kudos are registered under the Open Banking Directory as an account information service provider and are also regulated by the Financial Conduct Authority as a payment services firm under number 795791.

We are responsible for the secure transmission of any Shared Personal Data to Credit Kudos, for safely directing you to the website and for the safe receipt and usage of your Transaction Information.

You will not be required to share your banking password or log in details with either us or Credit Kudos.  Once you have given your explicit consent to share your bank account information on the website you will be directed to your own bank or building society’s login page where you will enter in your own login details directly.

Save as set out above or elsewhere in this Privacy Policy, we are not responsible for your direct data transmissions with Credit Kudos or with your own bank or building society.

 

How will my Shared Personal Data and Transaction Information be used?

Credit Kudos shall, subject to their own terms and conditions and privacy policy, and, if your bank or building society is registered to provide access under the Open Banking Directory, obtain, aggregate and analyse your Transaction Information and submit this back to us for the Permitted Purpose. By way of example, the Transaction Information that we shall receive is likely to include information relating to your income, outgoings and credit worthiness.

Credit Kudos shall be entitled to re-access your Transaction Information for up to 90 days from the date of your original search result in order to refresh the search results, obtain a snapshot of your data or gather additional data.

Credit Kudos shall hold the Shared Personal Data and the Transaction Information they receive and retain according to their own terms and conditions and privacy policy, available on their website, which you will be required to read and consent to once directed their via our website.

As Credit Kudos are also a credit reference agency they may also share and keep a record of your Shared Personal Data and Transaction Information.

 

Will you use my Transaction Information data for any other purpose?

The Transaction Information we receive about you will only be used for the Permitted Purpose.  We do not sell or share Transaction Information with any third party.

Save as set out above the information contained in the rest of this Privacy Policy deals with how we collate, use, transfer, store, delete and other terms applicable to your personal data including Shared Personal Data and Transaction Information.

 

Do I have to provide you with my consent to proceed?

We will only request consent to view your Transaction Data where it is necessary for verifying your income and expenditure and determining your eligibility for a loan with us. You are under no obligation to provide us with consent via Open Banking, but we will still require sight of your Transaction Data through other means (e.g. PDF downloads of your statements from your bank or printed paper statements) which will be stored, used and processed in accordance with this policy. Failure to provide the requested information will lead to your loan being refused.

Where your bank or building society have already permitted access to your Transaction Information you shall need to contact them directly in order to withdraw your consent under their particular Open Banking terms and conditions.

Planky

How will my personal data be shared and used for the purposes of Open Banking?

By proceeding with your loan application via our website you expressly consent to us sharing your personal, contact and loan application details (“the Shared Personal Data”) with our registered Open Banking partner, Friendly Score UK Ltd Limited (trading as Planky) who are also a FCA-regulated Account Information Service Provider (AISP), Credit Reference Agency, and analytical software company, offering Open Banking data aggregation services and bank account analytics.

During your loan application we shall safely and securely direct you to Plankys secure website for the purposes of granting Planky access to your bank or building society account information (“Transaction Information”).

Planky will use the information from the banks, financial institutions and other relevant parties that you have consented to share data with us, as part of the open banking solution. An application programming interface tool which comprises a set of definitions, communications protocols and tools, are used for the purposes of analysing, aggregating and consuming this data.

The information is used to provide data analytics services based on your information.

Your data may be combined with information you give to Planky and information they collect about you. Planky may use this information and the combined information for the purposes set out above (depending on the types of information we receive). This information will be reported back to us in the form of a completed search in order that we may continue to process your loan application (“the Permitted Purpose”). CLEVR Money may use this data to make automated lending decisions.

 

As soon as your Transaction Information is received it shall be aggregated with any other transaction information that you have provided Planky with consent to access and automatically analysed using machine learning detection and prediction models to provide us with a comprehensive view of your financial behaviour, including predicted and historic spend analysis, key merchants, balances, recurring expenditure, credit behaviour, stopped payments, and risk indicators including recent loan commitments, liquidity, stopped payments, returned direct debits, unarranged overdraft usage, and gambling.

 

Further information about Planky including their registered provider and regulatory status is available from https://www.planky.com

Is Open Banking secure with Planky?

Planky are Authorised and Regulated by the Financial Conduct Authority (FRN: 781963). They are also authorised to provide AISP Services (FRN: 821100).

 

We are responsible for the secure transmission of any Shared Personal Data to Planky, for safely directing you to the website and for the safe receipt and usage of your Transaction Information.

 

You will not be required to share your banking password or log in details with either us or Planky.  Once you have given your explicit consent to share your bank account information on the website you will be directed to your own bank or building society’s login page where you will enter in your own login details directly.

 

Save as set out above or elsewhere in this Privacy Policy, we are not responsible for your direct data transmissions with Planky or with your own bank or building society.

 

 

How will my Shared Personal Data and Transaction Information be used?

Planky shall, subject to their own terms and conditions and privacy policy, and, if your bank or building society is registered to provide access, obtain, aggregate and analyse your Transaction Information and submit this back to us for the Permitted Purpose. By way of example, the Transaction Information that we shall receive is likely to include information relating to your income, outgoings and credit worthiness.

 

Planky shall be entitled to re-access your Transaction Information for up to 90 days from the date of your original search result in order to refresh the search results, obtain a snapshot of your data or gather additional data.

 

Planky shall hold the Shared Personal Data and the Transaction Information they receive and retain according to their own terms and conditions and privacy policy, available on their website, which you will be required to read and consent to once directed their via our website.

 

As Planky are also a credit reference agency they may also share and keep a record of your Shared Personal Data and Transaction Information.

Will you use my Transaction Information data for any other purpose?  

The Transaction Information we receive about you will only be used for the Permitted Purpose.  We do not sell or share Transaction Information with any third party.

 

Save as set out above the information contained in the rest of this Privacy Policy deals with how we collate, use, transfer, store, delete and other terms applicable to your personal data including Shared Personal Data and Transaction Information.

 

Do I have to provide you with my consent to proceed?

We will only request consent to view your Transaction Data where it is necessary for verifying your income and expenditure and determining your eligibility for a loan with us, or to assist with assessing affordability for an existing loan. You are under no obligation to provide us with consent via Open Banking, but we will still require sight of your Transaction Data through other means (e.g. PDF downloads of your statements from your bank or printed paper statements) which will be stored, used and processed in accordance with this policy. Failure to provide the requested information will lead to your loan being refused.

 

Where your bank or building society have already permitted access to your Transaction Information you shall need to contact them directly in order to withdraw your consent under their particular Open Banking terms and conditions.

Are any of my other rights under this Privacy Policy affected?

Your individual data protection and privacy rights including the right to access, correct, delete, object, restrict, withdraw consent, request transfer and/or make a complaint, continue to apply to relevant personal data we control or process and are dealt with elsewhere in this Privacy Policy.

Under Open Banking as your personal data is shared by your bank or building society and accessed by PDS and, or, Credit Kudos and, or, Planky you may also be able to exercise your individual data protection and privacy rights against either of them pursuant to their own terms and conditions and privacy policies.

GDPR Principles-DDP
Law Bases fo Processing-DPP
Accoutability and Govenance-DPP
Individual Rights-DPP
Data Security-DPP
Pesonal Data Breaches-DPP
Data Retention-DPP
Data Accuracy and Limitation-DPP
Data Disclosures-DPP
Complaints-DPP
Open Banking
Definitions (DPP)

Financial Services Compensation Scheme (FSCS)

Important information about compensation arrangements

We are covered by the Financial Services Compensation Scheme (FSCS). The FSCS can pay compensation to depositors if a credit union is unable to meet its financial obligations. Most depositors - including most individuals and small businesses - are covered by the scheme. In respect of deposits, an eligible depositor is entitled to claim up to £85,000.

For joint accounts each account holder is treated as having a claim in respect of their share so, for a joint account held by two eligible depositors, the maximum amount that could be claimed would be £85,000 each (making a total of £170,000).

The £85,000 limit relates to the combined amount in all the eligible depositor's accounts with the credit union, including their share of any joint account, and not to each separate account.

For further information about the scheme (including the amounts covered and eligibility to claim) please download the FSCS Information Sheet, ask at your local branch, refer to the FSCS website - http://www.fscs.org.uk/ or call 0800 678 1100.

You can also refer to our Financial Services Compensation Scheme Information Sheet for more details.

Credit Reference Agency Information Notice (CRAIN)

In order to process credit applications you make we will supply your personal information to credit reference agencies (CRAs) and they will give us information about you, such as about your financial history. We do this to assess creditworthiness and product suitability, check your identity, manage your account, trace and recover debts and prevent criminal activity.

We will also continue to exchange information about you with CRAs on an ongoing basis, including about your settled accounts and any debts not fully repaid on time. CRAs will share your information with other organisations. Your data will also be linked to the data of your spouse, any joint applicants or other financial associates. This may affect your ability to get credit.

The identities of the CRAs, and the ways in which they use and share personal information, are explained in more detail on the below links:

https://www.transunion.co.uk/crain

https://www.equifax.co.uk/crain

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

Cookie Policy

You may encounter links to external websites when using our website, this policy does not cover these websites and we encourage you to view each website’s cookie policy.

What are Cookies

As is common practice with almost all modern websites this site uses cookies, which are tiny files that are downloaded to your computer to improve your experience. This page describes what information they gather, how we use that information and why we sometimes need to store these cookies.

For more general information on cookies see the Wikipedia article on HTTP Cookies...

Disabling Cookies

Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site.

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). As disabling cookies will usually result in also disabling certain functionality and features of this site, it is recommended that you leave on all cookies. If you are not sure whether you need them it is safer to leave them on, in case they are used to provide a service that you use.

The Cookies we use

These cookies are used by the website:

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This cookie is set by Facebook to show relevant advertisements to users and measure and improve those advertisements. The cookie also tracks the behavior of users across the web on sites that have Facebook pixel or Facebook social plugin.
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This cookies is installed by Google Universal Analytics to throttle the request rate to limit the collection of data on high traffic sites in an anonymous form.
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This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visited in an anonymous form.
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This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.

Third Party Cookies

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter during the use of this website.

Google Analytics

Google Analytics is one of the most widespread and trusted analytics solutions on the internet for helping website owners better understand how you use the website and discover ways that we can improve your experience.

These cookies may track things such as how long you spend on the site and the pages that you visit.  This helps our website to continue to produce engaging & personalised content.

We also use Google Analytics Demographic (see more details here) and Interest reports and Advertising Features (see more details here).  These cookies allow us to provide out website visitors with anonymised & aggregated data about visitors to our website and to allow us to provide relevant targeted advertising to visitors on our website.

If you would prefer to prevent Google Analytics collecting data in this way, Google have developed an opt-out browser add-on (see more details here).  You can also learn more about the opt-out and how to properly install the browser add-on here.

For more information on Google Analytics cookies, see the official Google Analytics page.

Members Area

The members area is hosted by an external company, Sercle. Their cookie policy can be viewed https://www.sercle.global/cookies/ For information about cookies used on the members area please contact Sercle on 0141 420 1010

More Information

If there is something that you aren't sure whether you need or not it's usually safer to leave cookies enabled in case it does interact with one of the features you use on our site. However if you are still looking for more information then you can contact us by email: hello@clevr.money.

Accessibility Policy

CLEVR Money endeavours to meet the needs of our members and are committed to ensuring our website is accessible to everyone, including people with disabilities.

All website content meets the W3C WAI's WCAG (Web Content Accessibility Guidelines) 2.0 A level standard and many of the Level AA standards.

This includes but is not limited to:

  • Ensuring images, form image buttons and image hot spots have appropriate alternative text

  • Semantic mark-up is used where appropriate, covering H tags (h1,h2,h3), lists (<ul>, <li>, <ol>,<dl>), and emphasised or special text (<strong>, <abbr>, <blockquote>)

  • The page navigation and content follows a logical order

  • Colour schemes are designed to ensure text content is clearly visible against other elements

  • Text and imagery will use the appropriate contrast ratio

  • The website can be navigable by screen readers

 

You can read more about the WCAG guidelines at http://www.w3.org/TR/WCAG20.


If you identify any accessibility issues or require further information please contact us on hello@clevr.money.

Common Bond Companies

You can apply for membership if you live or work in the below post code areas:

FY1 - FY8

PR1 - PR9

PR25, PR26

LA1 - LA4

Our partners are located in our common bond areas and outside it. Find out if your company is our partner and also find out which other companies that are not yet our partners but you still live or work within our common bond areas. 

Councils
Education
Food
Healthcare
Housing
Other
Blackpool Council
Aspire Academy
Bidfresh Ltd
Atlas BFW Management
Blackpool Coastal Housing
1 HomeCare
Fylde Borough Council
Baines Endowed C Of E Primary School
Bidfresh Ltd - Campbells North
Bloomfield Medical Centre
Blackpool Housing Company
Danbro
Preston City Council
Blackpool & Fylde College
Bidfresh Ltd – Campbells South
FCMS
Great Places Housing Group
Empowerment
Wyre Borough Council
Christ The King Catholic Academy
Bidfresh Ltd – Daily Fish
GP Led Health Care
Preston Community Gateway
Enveco
Devonshire Academy
Bidfresh Ltd - Direct Seafoods Colchester
Lancashire & South Cumbria NHS Foundation Trust
Progress Housing Association
N | Compass
Hawes Side Academy
Bidfresh Ltd - Direct Seafoods London
PDS Medical
Progress Housing Group
N Vision
Highfield Leadership Academy
Bidfresh Ltd – Head Office
Trinity Hospice
Regenda Group
One Fylde
Marton Primary Academy and Nursery
Bidfresh Ltd - Kingfisher Brixham
Victoria Hospital Trust
Renaissance-UK
South Shore Academy
Bidfresh Ltd - Kingfisher Midlands
Slater Gordon Solutions Motor
St Georges School
Bidfresh Ltd – Neve Fleetwood
Sustainable Energy First
St Mary's Catholic Academy
Bidfresh Ltd – R Noone & Son
YMCA Fylde Coast
Thames Primary Academy
Bidfresh Ltd – Taylor Foods
BES Utilities
Training2000
Elite Fine Foods
UCLan
South Lincs Foodservice
Unity Academy Blackpool
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