Archives: FAQ - Savings

In this section ‘monitoring’ means any listening to, recording of, viewing of, intercepting of, or taking and keeping records of calls, post, email, social media messages, in person face-to-face meetings and any other communications.

Telephone calls between us and you in connection with your application and the mortgage, savings account or core capital deferred shares will be recorded to make sure that we have a record of what has been discussed and what your instructions are. Certain in person meetings will also be recorded for the same purposes. We may monitor calls for quality control and staff training purposes.

We may monitor where permitted by law and we will do this where the law requires it. In particular, where we are required by the Financial Conduct Authority’s regulatory regime to record certain telephone lines or certain in person meetings we will do so.

Some of our monitoring may be to comply with regulatory rules, self regulatory practices or procedures relevant to our business; to prevent or detect crime; be in the interests of protecting the security of our communications systems and procedures; to have a record of what we have discussed with you and actions agreed with you; to protect you and to provide security for you (such as in relation to fraud risks on your account); and for quality control and staff training purposes.

Some of our monitoring may check for obscene or profane content in communications.

We may conduct short term carefully controlled monitoring of your activities on your mortgage, savings account or core capital deferred shares where this is necessary for our legitimate interests or to comply with our legal obligations. For instance, where we suspect fraud, money laundering or other crimes.

We need to ensure your personal data is accurate and up to date. You should tell us without delay if your details change (for example, if you move address) so that we can update our records. If you were introduced to us by a broker or other intermediary that is a data controller in its own right, you should contact them separately.

We are required by Money Laundering Regulations to collect and record personal data to confirm a customer’s identity.

To protect us against any fraudulent or other criminal activity we will check your details against, and share information with, fraud prevention agencies who maintain and share information on known and suspected fraudulent activity, such as Action Fraud.

We are required by law to report any suspicious transactions to the National Crime Agency, the police and other law enforcement agencies for crime detection and prevention purposes.

In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (CRAs). To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

We will use this information to:

• Assess your creditworthiness and whether you can afford to take the product;
• Verify the accuracy of the data you have 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.

We will continue to exchange information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. 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 from us they will place a search footprint on your credit file that may be seen by other lenders.

If you are making a joint application, or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until such time as you or your partner successfully files with the CRAs for a disassociation 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 within this privacy notice.

We will only send your data outside of the EEA to:

• Follow your instructions;
• Comply with a legal duty; or
• Work with other organisations for the purpose of providing a service on our behalf in connection with the operation of your account or membership.

If we do transfer information to a company outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We will use one of these safeguards:

• Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
• Put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this on the European Commission Justice website.
• Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website.

We are based in the UK but sometimes your personal information may be transferred outside the UK or the European Economic Area (EEA). When we do, there will be a contract in place to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.

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.