[Chris]

We are looking at our first request from a member for their account to be closed and their data to be erased.

We have looked at the guidance and examples of other credit unions’ policies and these all appear quite generic. The key questions arise from the expectation that CUs will retain data for reasons of legal obligation, however the challenge lies in which data this encompasses. The ID&V is clearly to be retained for AML reasons and where the membership details would be required this is clearly covered by the C&CBS Act. The uncertainty lies in the transaction data, which could be needed for audit purposes and loan data such as credit checks, which may be covered by potential legal disputes.

Does anyone have a procedure which covers these issues and is based on justifiable legal reasons for holding data which is sector specific (i.e. relevant to credit unions!)

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[Simon]

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Simon Haslam; Chair Derbyshire Community Bank

[Chris]

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