1Who we are
National Credit Intelligence ("the registry", "we") is an independent registry that connects the licensed lenders of Somalia. It is not part of any bank or lender and does not lend. In this policy, a "member" is a licensed institution that has joined the registry.
This policy covers the personal information the registry holds about people who apply for credit at a member, and about their guarantors; about the staff of members and of the registry who use its portals; and about anyone who writes to us through this website.
2The information we hold
About a person who applies for credit
- Who the person is: full name, date of birth, city of birth, mother's maiden name, national ID number, and passport number (or that the person has none), with phone number and address.
- The application: the credit applied for, employment and income, closest relatives, guarantors, the collateral offered, and the documents attached to it (a copy of the ID, proof of income, an employment contract and the collateral documents).
- The credit record: the loans the members report, each with its amount, instalment, repayment record, any lateness, rescheduling or write-off, and its collateral; guarantees given for other people's loans; and the monthly reports on loans that went live through the registry.
- What the registry makes from it: the credit reports and ratings released to members, and a record of the enquiries made on the person: which member asked, and when.
About a guarantor
The name, phone number, relationship to the borrower, occupation and income given on the application, and the national ID when the member records it with the loan.
About the people who use the portals
The name, username, e-mail address, institution and role of each user, and a record of what each user does in the portals: every sign-in, enquiry, change and document opened.
About people who write to us
What is typed into the membership application or the contact form on this website: a name, an e-mail address, an institution and a message.
3Where it comes from
- From the member the person applied to: the application, its documents, and, once the loan goes live, its monthly reports.
- From the other members, when the registry asks whether they know the person: each answers from its own books.
- From the registry's own records: the enquiries it has received and the reports it has released.
- From the person, when they write to us, ask for a correction or ask what we hold.
4Why we use it
- To answer a member that is about to lend: to find the right person, ask the other members, and send back one report with a rating and its reasons.
- To prevent fraud: the identity details and the collateral on every application are checked against what the registry already holds, to catch a false identity, one person under two IDs, several applications at once, or the same asset pledged twice. These checks are for the registry's staff: they are not passed on to the members.
- To keep the credit record accurate: members report their loans every month, and each report is checked before it is accepted.
- To correct mistakes.
- To keep the registry secure and its use lawful, through the record of who did what in the portals.
- To produce statistics for supervision, in which no person can be identified.
The registry does not sell personal information and does not use it for marketing, employment screening or any purpose other than these.
5Consent
A member asks the registry about a person only with that person's signed consent: on the application for credit, or, for a loan the member granted before it joined the registry, on a signed registry consent kept with the loan. The registry uses what it receives only for the purposes in section 4, under its agreements with its members and the laws of the Federal Republic of Somalia.
6Who can see it
- The member that asked receives the report and the rating. The other members appear in it only as Member A, Member B and so on: never by name.
- The other members receive the person's identifying details, so that each can look the person up in its own books. They are not told which member is asking or how much it is about to lend, and they never see the report.
- The registry's staff who handle enquiries and supervision see what their work needs: the person, the application's documents and what the members answer, but not the amount applied for, which only the member that asked sees. Every release is checked by a second person, and administrators, who manage user accounts, do not open applicants' documents.
- No one else, unless the law requires it: for example a court order, or a regulator acting with lawful authority.
A member sees only its own applications, its own loans and the requests addressed to it.
7How long we keep it
Information is kept for as long as the registry needs it for the purposes in section 4 and the law allows. In particular:
- An enquiry on a person is shown to members for 2 years.
- The rating measures repayment over the last 2 years; a debt written off counts in it for 7 years.
- A released report and its rating are kept exactly as released, so that they can always be shown again and checked.
- The record of what users do in the portals is kept for the registry's security and audit.
8How we protect it
- Access is by named account only; passwords are stored in a form that cannot be read back, and an account is locked after repeated failed sign-ins.
- Information travels encrypted between the portals and the registry's server.
- Documents are stored apart from the website and are opened only by the registry, the member that sent them, or the member that asked.
- Every sign-in, enquiry, change, release and document opened is recorded with the user, the time and the address it came from.
- The registry's data is backed up regularly, and each backup is checked when it is made.
9Your rights
- To know what we hold. You can ask whether the registry holds information about you, and receive a copy. We will ask you to prove who you are first, so that no one else can obtain your information.
- To have it corrected. If something reported about you is wrong, you can ask for it to be corrected, through any branch of the member that reported it or directly with the registry. The member checks it against its own books and, when it is wrong, corrects it within 10 business days. Every correction is logged.
- To ask questions or complain about how your information is handled, by contacting us as in section 12.
10The website and cookies
The public website uses no advertising or analytics cookies. The portals use one session cookie, which keeps a signed-in user signed in and ends with the session. If you tick "Remember me" on the sign-in page, your username or e-mail address (never your password) is kept in your own browser until you untick it.
What you send through the membership application or the contact form is used to answer you, and kept with the registry's correspondence.
11Changes to this policy
We may update this policy, for example when the law or the way the registry works changes. The date at the top shows when it was last changed.
12How to contact us
Write to us through the contact form, or use the registry's details below. To see or correct your own information, please say so in your message.