Archives: FAQ - Savings

Much of what we do with your personal information is not based on your consent, instead it is based on other legal grounds. For processing that is based on your consent, you have the right to take back that consent for future processing at any time. You can do this by contacting us. The consequence might be that we cannot send you some marketing communications, continue to publish your case study material or that we cannot take into account special categories of personal data such as information on your political beliefs or those concerning your health or if you are a vulnerable customer (but these outcomes will be relevant only in cases where we rely on explicit consent for this).

We will tell the broker or other intermediary who introduced you to us that you have withdrawn your consent only if they are our data processor (this means an organisation that is processing personal information on our behalf) or if we are required to do so when you exercise certain rights under data protection laws. You should make sure you contact them directly to withdraw your consent for what they do with your personal information as a data controller in their own right.

To comply with Payment Services Regulations we have to share some of your personal information with other payment service providers (e.g. banks and building societies) in some circumstances, such as when you ask us to share information about your account with them. Whilst those Payment Services Regulations mention ‘consent’ for this, ‘consent’ in that context does not have the same meaning as ‘consent’ under data protection laws. The legal grounds which may be relevant to this are compliance with our legal obligations, performance of our contract with you, our legitimate interests, or a combination of these. This is why if you ask to withdraw consent from what we do with your personal information, we may still need to hold and use your personal information under the Payment Services Regulations.

Data protection laws require us to explain what legal grounds justify our processing of your personal information (this includes sharing it with other organisations). For some processing, more than one legal ground may be relevant (except where we rely on consent). These are the legal grounds that are relevant to us:

11.1 Processing necessary to perform our contract with you (for the mortgage, savings product or core capital deferred shares) or for taking steps prior to entering into it (during the application stage):

a) Administering and managing your mortgage, savings product or core capital deferred shares and services relating to that, updating your records, tracing your whereabouts to contact you about your account or core capital deferred shares or doing this for recovering debt;
b) Sharing your personal information with other payment services providers such as when you ask us to share information about your account with them; and
c) All stages and activities relevant to managing your mortgage, savings account or core capital deferred shares including enquiry, application, administration and management of accounts or core capital deferred shares, illustrations, requests for transfers of equity or core capital deferred shares.

11.2 Where we consider that, on balance, it is appropriate for us to do so, processing necessary for the following legitimate interests which apply to us and in some cases other organisations (who we list below) are:

a) Administering and managing your mortgage, savings account or core capital deferred shares and services relating to that, updating your records, tracing your whereabouts to contact you about your account or doing this for recovering debt;
b) To test the performance of our products, services and internal processes;
c) For management and audit of our business operations;
d) To carry out searches at credit reference agencies, at the application stage and if borrowing is increased or where there are variations to the mortgage requirements, e.g. mortgage term or repayment amount changes;
e) To administer our good governance requirements such as internal reporting and monitoring;
f) For market research, analysis and developing statistics in relation to understanding our customers’ needs and circumstances in order to improve our service/products; and
g) When we share your personal information with the following people or organisations:

• Joint account holders, trustees and beneficiaries and any person with power of attorney over your affairs (in each case only if relevant to you);
• Other payment services providers such as when you ask us to share information about your account with them;
• Direct Debit Scheme (if you use direct debits);
• Other account holders or individuals when we have to provide your information to them because some money paid to you by them should not be in your account;
• The broker or other intermediary who introduced you to us;
• Our legal and other professional advisers, auditors and actuaries;
• Financial institutions and trade associations;
• Other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions;
• Buyers and their professional representatives as part of any restructuring or sale of our business or assets;
• Credit reference agencies (see below where we explain more); and
• Market research organisations that help us to develop and improve our products and services.

11.3 Processing necessary to comply with our legal obligations:

a) For compliance with laws that apply to us;
b) To fulfill our compliance obligations or administration required for Annual General Meeting (AGM) processes;
c) For establishment, defence and enforcement of our legal rights;
d) For activities relating to the prevention, detection and investigation of crime;
e) To carry out identity checks, anti-money laundering checks, and checks with fraud prevention agencies at the application stage and periodically after that;
f) To carry out monitoring and to keep records (see the ‘Do we do any monitoring involving the processing of your personal information?’ section below);
g) To deal with requests from you to exercise your rights under data protection laws;
h) To process information about a crime or offence and proceedings related to that (in practice this will be relevant if we know or suspect fraud); and
i) When we share your personal information with these other people or organisations:

• Joint account holders, trustees and beneficiaries, and the person with power of attorney over your affairs;
• Other payment services providers such as when you ask us to share information about your account with them;
• Other account holders or individuals when we have to provide your information to them because some money paid to you by them should not be in your account;
• Fraud prevention agencies;
• Law enforcement agencies and governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, the Financial Ombudsman Service, the Information Commissioner’s Office and under the Financial Services Compensation Scheme (depending on the circumstances of the sharing); and
• Courts and to other organisations where that is necessary for the administration of justice and to protect the security or integrity of our business operations.

11.4 Processing with your consent:

a) When you request that we share your personal information with someone else;
b) When we have made a mortgage offer to you and you consent that we share your personal data with the insurance broker Insure Green to assist with your insurance requirements;
c) When you agree to share details about you, your property or project, including images, as part of a case study. Those details could be used on our website, publications, brochures and shared with journalists or other relevant organisations;
d) For direct marketing communications; and
e) For some of our processing of special categories of personal data such as those concerning your health or if you are a vulnerable customer (and it will be explained to you when we ask for that explicit consent what purposes, sharing and use it is for).

11.5 Processing for a substantial public interest under laws that apply to us where this helps us to meet our broader social obligations such as:

a) Processing of your special categories of personal data such as about your health or if you are a vulnerable customer;
b) Processing that we need to do to fulfil our legal obligations and regulatory requirements;
c) When we share your personal information with other people and organisations if they need to know that you are a vulnerable customer and your relatives, social services, your carer, or the person who has power of attorney over your affairs; and
d) To protect vital interests.

We will generally collect your personal information from you directly. If you are introduced to us by a broker or other intermediary, we will obtain some personal information about you indirectly from them when they introduce you to us.

In addition, we obtain your personal information from other sources such as someone with authority to deal with your financial affairs, fraud prevention agencies, credit reference agencies, your employer, your landlord, other lenders, HMRC, the Department for Work and Pensions, publicly available directories and information (e.g. telephone directory, social media, internet, news articles, Charity Commission, Scottish Charity Regulator), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies.

Some of the personal information obtained from credit reference agencies will have originated from publicly accessible sources. In particular, credit reference agencies draw on court decisions, bankruptcy registers and the electoral register (also known as the electoral roll). We explain more about credit reference agencies below. We have also mentioned above in the lists of personal information that we process some of the CRAs’ other sources of information (which are our own source of information too).

If you make a joint application (e.g. with your spouse, partner or family member), we will also collect the personal information mentioned above about that person. If you look now at the ‘What are the legal grounds’ section (below) you will see reference to consent and a description of some limited scenarios where it may be relevant to what we do with personal information. If we ask you to obtain consent from the joint applicant (such as for marketing) you should do that using the consent capture mechanism that we give or make available to you on the application form for that purpose.

If there is somebody who has authority to deal with your affairs, that person will see this privacy notice when we make contact with him/her directly.

This includes:

• Your debit card details to process your initial deposit (where you apply for your savings account online);
• Where a person other than the savings account holder makes a withdrawal from the account, information about that person and the transaction;
• Where a withdrawal is made to another person, information about that person and the transaction;
• Information about your tax position including citizenship, tax residency and Tax Identification Number (where applicable); and
• Information relating to transactions, i.e. source of funds for deposits and purpose of withdrawals.

This includes:

• Your financial details e.g. your salary and details of other income, other assets and investments, details of your savings, details of your expenditure, and details of account(s) held with other providers if you pay your mortgage from those account(s);
• Details of your existing borrowings and loans;
• Personal information about you and your credit history which we obtain from credit reference agencies including data which originates from Royal Mail (UK postal addresses), local authorities (electoral roll), the insolvency service, Companies House, other lenders and providers of credit (who supply data to the CRAs) and court judgments, decrees and administration orders made publicly available through statutory public registers (see the ‘How do we share your information with fraud prevention agencies?’ section below);
• Information about your employment status including length of service and background, skills and experience, whether you are employed, self‑employed, retired or receive benefits;
• Information about any external directorships or trustee roles that you hold;
• Information about your occupier status, such as whether you are a tenant including landlord name and address (if applicable), live with parents or are an owner occupier of the property in which you live at the time of your application;
• Information which is relevant for your residency and/or citizenship status, such as your nationality, your length of residency in the UK and/or whether you have the permanent right to reside in the UK;
• Your marital status, family, lifestyle or social circumstances if relevant to the mortgage product (e.g. the number of dependents you have and their ages); and
• Source of funds for any over payments.

This includes:

• Your title, full name, any previous names (where applicable) and your contact details, including for instance your email address and contact numbers;
• Your home address, correspondence address (where different from your home address) and address history;
• Your date of birth and/or age, e.g. to make sure that you are eligible to apply for the product and/or that it is suitable for you;
• Your nationality and national identifiers, for example, national insurance number, passport and driving licence;
• Your signature;
• Telephone, voice recording, video images (including CCTV) and IP address where known;
• Your status as a Politically Exposed Person (PEP) or relative or close associate of a PEP (if applicable);
• Personal information which we obtain from fraud prevention agencies (see the section below on fraud prevention agencies);
• Details of the relationships, products and services you hold with us, including financial details, for example, balance, transactions, how you operate the accounts and services;
• Your occupation;
• Some special categories of personal data such as information on your political beliefs or those concerning your health or if you are a vulnerable customer; and
• Details of any unspent criminal convictions, pending convictions, bankruptcy/receivership, county court judgements, court records and pending orders. This will also include any sanctions or suspensions from any financial services regulator.

This will depend on the products or services you apply for and obtain from us. Before we explain what particular information we need in relation to our mortgages, savings products or core capital deferred shares, we will explain what information is relevant to all of our products and services.