Privacy and uses of Data
Privacy statement
If you already have a loan or are thinking about applying for one, please make sure you have read our privacy statement .
Uses of data
A service of quality
We place paramount importance on customer service and aim to meet your expectations on every occasion. To achieve this aim we need accurate personal information about you. We have a legal obligation under the Data Protection Act to ensure that all information held and processed about you complies with the principles of the Act.
Data Protection Act
The Data Protection Act puts obligations on users of personal information and lays down principles for its use. One principle states that information has to be processed fairly and lawfully. This means that you are entitled to know how we intend to use any information you provide. You can then decide whether you want to give it to us.
To provide outstanding customer service we need accurate customer information. You can help by informing us whenever your circumstances change.
Organisations must lodge a notification with the Information Commissioner describing the purposes for which they process personal information. The details are publicly available from the Commissioner’s Office at Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF (Tel: 01625 545745, Fax: 01625 524510). Alternatively, see the Commissioner's website at www.informationcommissioner.gov.uk .
How do we use your personal information?
Our main use of your personal information is to look after your account or to provide the specific service you require. Some details we obtain elsewhere: from credit reference agencies or your employer, for instance.
Your contact details may be used by us for market research and statistical analysis. Occasionally, we may contact you by letter, telephone, email, SMS (text message) or MMS to inform you about other products, services and special offers that may interest you. We try to limit our customer contact programme to acceptable levels, but if you wish to exercise your right to opt out, simply write to us.
Remember, however, that opting out could stop us contacting you about any of our products or services that may benefit you. For example, you may not hear about a new savings or mortgage product that offers you a better rate or saves you money. Unless you have given us your consent, we will not provide information about you to companies outside our group to use for their own marketing purposes. We disclose information about our customers only with their consent, or if we are required to do so by law. Sometimes we need to give information to our agents and subcontractors, so that they can provide a particular service for us. Sometimes, these companies may be located abroad in countries that do not have data protection laws. In these circumstances, we always take great care to ensure that your personal information is kept safe and secure. We will use your details to assist us in understanding individual needs and business trends in order to improve the products and services we offer.
We are also committed to meeting the standards set by the Banking and Mortgage Code, copies of which are available on request. Occasionally, the Banking and Mortgage Code compliance review bodies audit a sample of our customer records to assess our compliance with the Code. Whenever this happens, strict confidentiality conditions are always imposed.
Under the Data Protection Act you have the right of access to information we hold about you on our records. The Act allows us to charge a fee of $10 for this service. If anything is inaccurate or incorrect, please let us know and we will correct it.
If you do not want to receive unsolicited mail from other companies, you can prevent this by registering with the Mailing Preference Service. In addition, the Telephone and Fax Preference Services enable you to object to receiving unsolicited marketing phone calls or faxes from other companies. To register, simply telephone the appropriate number:
Mailing Preference: 020 7291 3310
Telephone Preference: 020 7291 3320
Fax Preference: 020 7291 3330
For more details about all of the preference services, please see the Direct Marketing Association's website at www.dma.org.uk .
Credit referencing
If you apply for any of our credit-based products (e.g. a mortgage, personal loan or credit card), we will perform a search with a credit reference agency. The agency will keep a record of the search. After you open a credit-based product, we will provide the agency with regular information about how you use it. Other lenders may use this to make decisions on future applications for credit. It may also be used for tracing debtors and to prevent fraud.
When opening accounts we may search public records such as the electoral roll that are available from credit reference agencies to help us verify your identity.
Occasionally we search credit and fraud prevention agency records, as well as our own records, to manage your account and take credit decisions such as whether to offer credit or continue to offer existing credit. These searches are not seen or used by other lenders to assess your ability to obtain credit.
'Associations' linking your financial records may be created on credit reference agency records when you apply for accounts in joint names. Your financial records, and those of anyone financially associated with you, may be considered in any future applications you make.
You have the right to apply to the credit reference agencies for a copy of your credit file. If there is anything incorrect on your credit file, you have the right to ask the agencies to add a Notice of Correction.
We mainly use Experian Limited, although occasionally we use Equifax plc or Callcredit plc, whose addresses are:
If you have been refused credit, you can get advice from your local Trading Standards Department, Citizens Advice Bureau or Consumer Advice Centre.
Credit scoring
When you apply to us for a credit based product, the details you provide, the information we already have and information from credit reference agencies are used to assess credit risk, using a technique called 'credit scoring'. Various factors in all these details help us to assess the risk. A score is given to each factor and a total credit score obtained. If your score is above a confidential pre-set pass score, the application is likely to succeed. For more details, please ask for our 'Credit Scoring' leaflet.
Crime prevention and detection
We have systems that protect our customers and ourselves against fraud and other crime. Customer information can be used to prevent crime and trace those responsible. We may check your details with fraud prevention agencies. If you give us false or misleading information and we suspect fraud, we will record this.
We and other organisations may use and search these records to help us to:
- make decisions about credit and related services for you and members of your household;
- make decisions on motor, household, life and other insurance proposals and insurance claims for you and members of your household;
- trace debtors, recover debt, prevent fraud and to manage your accounts or insurance policies; and
- check your identity to prevent money laundering, unless you provide us with other satisfactory proof of identity.
Money laundering and statutory obligations
To comply with money laundering regulations, and to help stop criminals using financial products or services to launder money, there are times when we need to confirm (or reconfirm) the name and address of our customers. We may need to do this whether you are applying to be a new customer or have been one for some time. For more details about identity checks on account opening, please ask for our leaflet 'Your Personal Details – How to help us prevent crime'.
Some Acts of Parliament oblige us to disclose information about our customers to certain bodies with statutory powers. For example, we must give information to authorised benefit fraud investigators where fraudulent benefit claims are suspected. In addition, the Inland Revenue has the statutory authority to audit our customers' accounts from time to time.
Email
If you email us, or give us your email address, we will keep a record of it. We may use it to contact you occasionally about other products and services that may interest you, unless you ask us not to do so (as detailed above). We will not give your email address to any unauthorised third parties.
When emailing us, always use the email facility on our website to make sure that the content of your email is secure. If you send us email in other ways, remember that it will be 'insecure' and could be intercepted. If you do send us 'insecure' email, please keep the amount of confidential information you include to a minimum. We will do likewise when we reply.
Telephone calls
We may record telephone conversations to offer you additional security, resolve complaints and improve our service standards. Conversations may also be monitored for staff training purposes.
Responsibility for customer confidentiality
All our employees are personally responsible for maintaining customer confidentiality. We provide training and education to all our staff to remind them about their obligations. Our policies and procedures are regularly audited and reviewed.
Sensitive information
The Data Protection Act defines information about the following as 'sensitive' (racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences). If you apply to us for insurance, a pension, health insurance or life assurance, we may ask you for some 'sensitive' details. We will only use this information to provide the service you require and we will ask for your explicit consent. Some transactions that you (or an additional cardholder) make on a card account may cause sensitive or confidential details to appear on your statement. If your card is used for such transactions, we believe that the details appear on your statement with your explicit consent.
Additional needs
We are committed to meeting the needs of all our customers. If you have a hearing or speech impairment, you can use Typetalk whenever you contact us. For the visually impaired, we can provide documents in large print, braille or on audio cassette.