Our Privacy Notice

Before we begin

This notice (Privacy Notice) applies to personal information held by members of the [CLIENT] Group as data controllers, as described below. It explains what information we collect about you, how we’ll use that information, who we’ll share it with, the circumstances when we’ll share it and what steps we’ll take to make sure it stays private and secure. It continues to apply even if your agreement or other products and services with us ends.

This Privacy Notice covers any personal products or services you have with us. Sometimes we may need to provide you with separate or further information about specific products and services. This information will also apply.

Some of the links on our websites lead to other [CLIENT] or non-[CLIENT] websites with their own privacy notices, which may be different to this notice. You’ll need to make sure you’re happy with their privacy notices when using those other sites.

Wherever we’ve said ‘you’ or ‘your’, this means you, any authorized person on your account (e.g. trustees or executors, attorneys under a Power of Attorney) and other related people (including authorized signatories, partners, members, and trustees).

When we say ‘we’, we mean [CLIENT] Group companies which act as a data controller in respect of your personal data. Unless otherwise stated below, the data controller for the purposes of this notice will be [CLIENT] Bank Plc

The following [CLIENT] Group companies will act as a data controller where you hold a product or service with them: [CLIENT] Life (UK) Limited; [CLIENT] Trust Company (UK) Limited; [CLIENT] Executor and Trustee Company (UK) Limited; Trustees of The [CLIENT] Self-Invested Personal Pension; and [CLIENT] Finance Limited.

The address for the [CLIENT] Group companies set out in this notice is [Address]. If you’d like to get in touch with us, you can also find contact details below.

What information we collect

We’ll only collect your information in line with relevant regulations and law. We may collect it from a range of sources and it may relate to any of our products or services you apply for, currently hold or have held in the past. We may also collect information about you when you interact with us, e.g. visit our websites or mobile channels, call or visit us, or ask about any of our products and services.

Some of it will come directly from you. It can also come from other intermediaries, other [CLIENT] companies, we offer or other sources you’ve asked us to obtain information from. We might also get some of it from publicly available sources.

The information we collect may include:

Information that you provide to us, e.g.:

 

  • personal details, e.g. name, previous names, gender, date, and place of birth;
  • contact details, e.g. address, email address, landline, and mobile numbers;
  • information concerning your identity e.g. photo ID, passport information, National Insurance number, National ID card and nationality;
  • market research, e.g. information and opinions expressed when participating in market research;
  • user login and subscription data, e.g. login credentials for phone and online banking and mobile banking apps;
  • other information about you that you give us by filling in forms or by communicating with us, whether face-to-face, by phone, email, online, or otherwise;
  • if our relationship arises out of an insurance policy or claim, we may also collect:
    • information regarding your family members or other third parties who might be covered by or benefit from your insurance policy or be financially dependent on you;
    • information which is relevant to your insurance policy including details of previous policies and claims history. This will depend on the type of policy that you have with us.
    • lifestyle information. For example, if you apply for a life insurance policy, we may ask for details such as your status as a smoker and alcohol consumption;
    • details about your physical or mental health which are relevant to your insurance policy or claim. For example, if you make a claim we may ask for medical information which relates to your claim;
    • details about your criminal convictions or related information. This will include information relating to offenses or alleged offenses; and
    • any other information which is relevant to a claim that you make.

 

 

Information we collect or generate about you, e.g:

 

  • your financial information and information about your relationship with us, including the products and services you hold, the channels you use and your ways of interacting with us, your ability to get and manage your credit, your payment history, transactions records, market trades, payments into your account including salary details and information concerning complaints and disputes;
  • information we use to identify and authenticate you, e.g. your signature and your biometric information, such as your voice for voice ID, additional information that we receive from external sources that we need for compliance purposes;
  • geographic information, e.g. about which branches or ATMs you use;
  • information included in customer documentation, e.g. a record of advice that we may have given you;
  • marketing and sales information, e.g. details of the services you receive and your preferences;
  • cookies and similar technologies we use to recognize you, remember your preferences and tailor the content we provide to you – our cookie policy contains more details about how we use cookies and can be found at [Insert Link of Cookie Policy];
  • risk rating information, e.g. credit risk rating, transactional behavior and underwriting information;
  • investigations data, e.g. due diligence checks, sanctions, and anti-money laundering checks, external intelligence reports, content and metadata related to relevant exchanges of information between and among individuals, organizations, including emails, voicemail, live chat;
  • records of correspondence and other communications between us, including email, live chat, instant messages and social media communications;
  • information that we need to support our regulatory obligations, e.g. information about transaction details, detection of any suspicious and unusual activity and information about parties connected to you or these activities.

Information we collect from other sources, e.g.:

  • information you’ve asked us to collect for you, e.g. information about your accounts or holdings with other companies including transaction information;
  • information from third-party providers, e.g. information that helps us to combat fraud or that relates to your social interactions (including your communications via social media, between individuals, organizations, prospects and other stakeholders acquired from companies that collect combined information);
  • if our relationship arises out of an insurance policy or claim, we may also collect:
    • information relating to your insurance application where you apply for a policy via a comparison website or aggregator
    • information relating to your medical records, with your agreement;
    • information relating to your insurance claims history;
    • information from other parties involved in your insurance policy or claim; and
    • information from publically available sources

 

How we’ll use your information

We’ll only use your information where we have your consent or we have another lawful reason for using it. These reasons include where we:

  • need to pursue our legitimate interests;
  • need to process the information to enter into or carry out an agreement we have with you;
  • need to process the information to comply with a legal obligation;
  • believe the use of your information as described is in the public interest, e.g. for the purpose of preventing or detecting crime;
  • need to establish, exercise or defend our legal rights; or
  • we need to use your information for insurance purposes.

The reasons we use your information include to:

  • deliver our products and services;
  • carry out your instructions, e.g. to fulfill a payment request or make a change to your insurance policy;
  • carry out checks in relation to your creditworthiness; manage our relationship with you, including (unless you tell us otherwise) telling you about products and services we think may be relevant for you;
  • understand how you use your accounts and services;
  • support banking operations support;
  • prevent or detect crime including fraud and financial crime, e.g. financing for terrorism and human trafficking;
  • investigate and resolve complaints;
  • ensure security and business continuity;
  • risk management;
  • provide online banking, mobile apps and other online product platforms;
  • implement product and service improvement;
  • undertake data analytics to better understand your circumstances and preferences so we can make sure we can provide you with the best advice and offer you a tailored service;
  • protect our legal rights and comply with our legal obligations;
  • correspond with solicitors, surveyors, valuers, other lenders, conveyancers and third-party intermediaries;
  • undertake system or product development and planning, insurance, audit and administrative purposes.
  • recover money which you owe (where you have not paid for your insurance policy);
  • if our relationship arises out of an insurance policy or claim, we will also use your information to:
    • evaluate your insurance application and provide you with a quotation;
    • handle or monitor any claims which you make or which arise under your insurance policy;
    • where relevant, bring a claim against a third party; and
    • apply for and claim on our own insurance policies.

Further details of how we’ll use your information can be found in the Appendix below.

 

How we make decisions about you

We may use automated systems to help us make decisions, e.g. when you apply for products and services, to make credit decisions and to carry out fraud and money laundering checks. We may use technology that helps us identify the level of risk involved in customer or account activity, e.g. for credit, fraud or financial crime reasons, or to identify if someone else is using your card without your permission.

If you are an insurance customer, we may use automated systems to help us make decisions, e.g. to determine whether or not we can offer you insurance and at what price. We may base our decision on factors such as health, lifestyle and occupational information, as well as the level of cover being requested.

You may have a right to certain information about how we make these decisions. You may also have a right to request human intervention and to challenge the decision. More details can be found in the ‘Your rights’ section below.

Tracking or recording what you say or do

To help keep you and your money safe, we may record details of your interactions with us. We may record and keep track of conversations you have with us including phone calls, face-to-face meetings, letters, emails, live chats, video chats and any other kinds of communication. We may use these recordings to check your instructions to us, assess, analyze and improve our service, train our people, manage risk or to prevent and detect fraud and other crimes. We may also capture additional information about these interactions, e.g. telephone numbers that you call us from and information about the devices or software that you use. We use closed-circuit television (CCTV) in and around our sites and these may collect photos or videos of you, or record your voice.

Compliance with laws and regulatory compliance obligations

We’ll use your information to meet our compliance obligations, to comply with other laws and regulations and to share with regulators and other authorities that [CLIENT] Group companies are subject to. This may include using it to help detect or prevent crime (including terrorism financing, money laundering, and other financial crimes). We’ll only do this on the basis that it’s needed to comply with a legal obligation, it’s in our legitimate interests and that of others or to prevent or detect unlawful acts.

Marketing and market research

We may use your information to provide you with details about [CLIENT] products and services, and also products and services from our partners and other relevant third parties. We may send you marketing messages by post, email, telephone, text or secure messages. You can change your mind on how you receive marketing messages or choose to stop receiving them at any time. To make that change, please contact us in the usual way.

If you ask us not to send you marketing, it may take us a short period of time to update our systems and records to reflect your request, during which time you may continue to receive marketing messages. Even if you tell us not to send you marketing messages, we’ll continue to use your contact details to provide you with important information, such as changes to your terms and conditions or if we need to tell you something to comply with our regulatory obligations.

We may use your information for market research and to identify trends. Market research agencies acting on our behalf may get in touch with you by post, telephone, email or other methods of communication to invite you to take part in research. We won’t invite you to take part in research using a communication method if you’ve asked us not to get in touch that way. Any responses that you provide whilst participating in market research will be reported back to us anonymously unless you give us permission for your details to be shared.

Who we might share your information with

We may share your information with others where lawful to do so including where we or they:

  • need to in order to provide you with products or services you’ve requested, e.g. fulfilling a payment request;
  • need to in order to provide you with your insurance policy or to administer your claim;
  • have a public or legal duty to do so, e.g. to assist with detecting and preventing fraud, tax evasion, and financial crime;
  • need to in connection with regulatory reporting, litigation or asserting or defending legal rights and interests;
  • have a legitimate business reason for doing so, e.g. to manage risk, verify your identity, enable another company to provide you with services you’ve requested, or assess your suitability for products and services;
  • have asked you for your permission to share it, and you’ve agreed.

We may share your information for these purposes with others including:

  • other [CLIENT] group companies and any sub-contractors, agents or service providers who work for us or provide services to us or other [CLIENT] Group companies (including their employees, sub-contractors, service providers, directors, and officers);
  • any joint account holders, trustees, beneficiaries or executors;
  • people who give guarantees or other security for any amounts you owe us;
  • people you make payments to and receive payments from;
  • your beneficiaries, intermediaries, correspondent and agent banks, clearing houses, clearing or settlement systems, market counterparties and any companies you hold securities in through us, e.g. stocks, bonds or options;
  • other financial institutions, lenders and holders of security over any property you charge to us, tax authorities, trade associations, credit reference agencies, payment service providers and debt recovery agents;
  • any fund managers who provide asset management services to you and any brokers who introduce you to us or deal with us for you;
  • any entity that has an interest in the products or services that we provide to you, including if they take on the risk related to them;
  • any people or companies where required in connection with potential or actual corporate restructuring, merger, acquisition or takeover, including any transfer or potential transfer of any of our rights or duties under our agreement with you;
  • law enforcement, government, courts, dispute resolution bodies, our regulators, auditors and any party appointed or requested by our regulators to carry out investigations or audits of our activities;
  • other parties involved in any disputes, including disputed transactions;
  • fraud prevention agencies who’ll also use it to detect and prevent fraud and other financial crime and to verify your identity;
  • anyone who provides instructions or operates any of your accounts, products or services on your behalf, e.g. Power of Attorney, solicitors, intermediaries, etc;
  • anybody else that we’ve been instructed to share your information with by either you, a joint account holder or anybody else who provides instructions or operates any of your accounts on your behalf;
  • our card processing supplier(s) to carry out credit, fraud and risk checks, process your payments, issue and manage your card;
  • if our relationship arises out of an insurance policy or claim, we will also share your information with:
    • other parties involved in providing your insurance policy such as the intermediary or the insurer who provides your policy;
    • third parties involved in the administration of the relevant insurance policy or claim including loss adjusters, claims handlers, private investigators, experts and our advisers; and
    • where relevant, medical experts and rehabilitation providers.

 

Sharing aggregated or anonymised information

We may share aggregated or anonymised information within and outside of the [CLIENT] Group with partners such as research groups, universities or advertisers. You won’t be able to be identified from this information, e.g. we may share information about general spending trends in the UK to assist in research.

 

How long we’ll keep your information

We keep your information in line with our data retention policy. For example, we’ll normally keep your core banking data for a period of seven years from the end of our relationship with you. This enables us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes such as managing your account and dealing with any disputes or concerns that may arise.

We may need to retain your information for a longer period where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate purposes, e.g. to help us respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators, etc.

If we don’t need to retain information for this period of time, we may destroy, delete or anonymise it more promptly.

Transferring your information overseas

Your information may be transferred to and stored in locations outside the European Economic Area (EEA), including countries that may not have the same level of protection for personal information. When we do this, we’ll ensure it has an appropriate level of protection and that the transfer is lawful. We may need to transfer your information in this way to carry out our contract with you, to fulfil a legal obligation, to protect the public interest and / or for our legitimate interests. In some countries the law might compel us to share certain information, e.g. with tax authorities. Even in these cases, we’ll only share your information with people who have the right to see it.

You can obtain more details of the protection given to your information when it’s transferred outside the EEA by contacting us using the details in the ‘More details about your information’ section below.

Your rights

You have a number of rights in relation to the information that we hold about you. These rights include:

  • the right to access information we hold about you and to obtain information about how we process it;
  • in some circumstances, the right to withdraw your consent to our processing of your information, which you can do at any time. We may continue to process your information if we have another legitimate reason for doing so;
  • in some circumstances, the right to receive certain information you have provided to us in an electronic format and / or request that we transmit it to a third party;
  • the right to request that we rectify your information if it’s inaccurate or incomplete;
  • in some circumstances, the right to request that we erase your information. We may continue to retain your information if we’re entitled or required to retain it;
  • the right to object to, and to request that we restrict, our processing of your information in some circumstances. Again, there may be situations where you object to, or ask us to restrict, our processing of your information but we’re entitled to continue processing your information and / or to refuse that request.

You can exercise your rights by contacting us using the details set out in the ‘More details about your information’ section below. You also have a right to complain to the UK Information Commissioner’s Office by visiting www.ico.org.uk, or to the data protection regulator in the country where you live or work.

 

Credit Reference Checks, Fraud and Money Laundering

Credit Reference Checks

If you apply for new products or services (including credit like a mortgage, personal loan or credit card), we may perform credit and identity checks on you with one or more credit reference agencies (CRAs). When you use our banking services, we may also make periodic searches at CRAs to manage your account with us.

To do this, we’ll supply your personal information to CRAs and they’ll give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply us with both public (including the electoral register) and shared credit information, financial situation, history and fraud prevention information.

We may use this information to:

  • assess if we can offer you credit and whether you can afford to take the product you applied for;
  • verify the accuracy of the data you’ve provided to us;
  • prevent criminal activity, fraud and money laundering;
  • manage your account(s);
  • trace and recover debts;
  • ensure any offers provided to you are appropriate to your circumstances.

We’ll continue to exchange information about you with CRAs while you have a relationship with us. We’ll also inform the CRAs about your repayment history. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs.

When CRAs receive a search request from us they’ll place a search footprint on your credit file that may be seen by other lenders. If you apply for a bank account or credit (such as where you apply for a mortgage, loan or credit card), we’ll get details of your credit history from a CRA (and share information about you with the CRA) and use this information to work out how much you can afford to borrow or pay back. We may also carry out further credit checks on you while you’re a customer to maintain an accurate and up-to-date record of your credit history. We may use your information to verify the accuracy of the information you’ve provided to us, prevent criminal activity, fraud and money laundering, manage your account(s), trace and recover debts and ensure any offers provided to you are appropriate to your circumstances.

If you’re making a joint application, or tell us that you have a spouse or financial associate, we’ll link your records together. You should discuss this with them, and share this information with them before submitting the application. CRAs will also link your records together and these links will remain on your and their files until you or your partner successfully files for a disassociation with the CRAs to break that link.

The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail on their websites. They’ve created a joint document called the Credit Reference Agency Information Notice (CRAIN) which is accessible from each of the three CRAs – clicking on any of these three links will also take you to the same CRAIN document:

Credit reference agencies:                                                    

To comply with the law and for our own legitimate interest to enable us to assess and manage risk, we can share details about your financial situation and financial history with CRAs, fraud prevention agencies, etc. This includes information on any bank accounts or credit you have with us, including:

  • how you manage your bank accounts or credit;
  • if you owe us money;
  • if we have concerns about financial crime;
  • if you haven’t kept up with your payments or paid off what you owe us (unless there’s a genuine dispute over how much you owe us), or if you’ve agreed and stuck to a repayment plan.

Fraud Prevention Agencies

 

We’ll carry out checks with fraud prevention agencies for the purposes of preventing fraud and money laundering, and to verify your identity before we provide products and services to you. These checks require us to process personal information about you.

 

The personal information you provide or which we’ve collected from you, or received from third parties, will be used to carry out these checks in order to prevent fraud and money laundering, and to verify your identity.

 

We’ll process personal information, such as your name, address, date of birth, contact details, financial information, employment details, and device identifiers e.g. IP address.

 

We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

 

We process your personal data on the basis that we have a legitimate interest in preventing fraud and money laundering and to verify your identity. This enables us to protect our business and to comply with laws that apply to us. This processing is also a contractual requirement of any of our products or services you use.

 

Fraud prevention agencies can hold your personal data for different periods of time. If they’re concerned about a possible fraud or money laundering risk, your data can be held by them for up to six years.

 

Consequences of Processing

 

If we, or a fraud prevention agency, have reason to believe there’s a fraud or money laundering risk, we may refuse to provide the services and credit you’ve requested. We may also stop providing existing products and services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services to you. The information we hold about you could make it easier or harder for you to get credit in the future.

 

To find out more about credit and fraud checks, read our ‘Guide to Credit Scoring, Credit Reference and Fraud Prevention Agencies’ leaflet. You can get it from our website, in any of our branches or you can request a paper copy by contacting us in your preferred way. To find out more about fraud prevention agencies and how they manage your information, please visit https://www.cifas.org.uk/privacy-notice.

What we need from you

You’re responsible for making sure the information you give us is accurate and up to date, and you must tell us if anything changes as soon as possible. If you provide information for another person (for example, a joint account holder, a beneficiary under an insurance policy or a dependant), you’ll need to direct them to this notice.

 

How we keep your information secure

We use a range of measures to keep your information safe and secure which may include encryption and other forms of security. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information.

More details about your information

If you’d like further information on anything we’ve said in this Privacy Notice, or to contact our Data Protection Officer, contact us at [Address and Email Address].

This Privacy Notice may be updated from time to time and the most recent version can be found at [Client].co.uk/privacy-notice

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