Privacy Policy

How Your Personal Data Is Collected:

The type of personal data we collect about you and how it is used depends on your contract with us, your needs, your relationship with us, and the products and services you own or inquire about.

Categories of Personal Data We Collect:

We collect and record your data from various sources; however, we primarily rely on information provided directly by you.

We collect and process this data to deliver our products and services, which include:

  • Personal data, including your name, date of birth, passport, and identification information.
  • Contact details, including your phone number, email address, and postal address.
  • Financial data, including account information, financial history, credit reference agencies, fraud prevention agencies, and property agents.
  • Proof of income, such as payslips or bank statements.
  • Details about your health and lifestyle, required to meet our regulatory obligations, including those related to responsible lending.
  • Business client information, including business details, contact information, and shareholding structures.
  • Special categories of personal data, including information about your physical and mental health—only to provide you with additional support in relation to our services and only with your explicit consent.
  • Transaction details, including payments you make and receive.
  • Banking information, including account numbers and any information you provide to enable payment initiation services (a service that allows a third party to instruct us to make payments from your account on your behalf).

Why We Collect This Data:

We may use your personal information only if we have a valid reason to do so and to comply with legal and regulatory requirements imposed on us in each jurisdiction, or for legitimate business purposes. A legitimate reason exists when we have a business or commercial reason to use your information. However, even in such cases, it must not unfairly go against what is right and best for you.

We collect this data to:

  • Know our clients’ activities, including anti-money laundering checks
  • Maintain banking and financial relationships with clients
  • Administer our products and services
  • Process client transactions and instructions
  • Prevent and investigate financial crime
  • Resolve any legal disputes
  • Carry out compliance-related activities, such as regulatory and tax reporting obligations
  • Improve our services through research and statistical analysis

The primary reason we collect this information is to perform the services you have contracted with us for. Without this information, we cannot meet our legal and regulatory obligations, so it is essential that we collect it.

We will not request more personal data than necessary. Once we collect the information we need, we will not use it for any other purpose without informing you and obtaining your consent.

We also use your data to develop and enhance our services for you and other customers, ensuring the products and services we offer continue to deliver positive outcomes, and to protect our legitimate interests.

Information We Collect

  • Payment and transaction data.
  • Data obtained through your use of our online and telephone banking services. This includes your personal profile, how you authenticate yourself when accessing these services, and other information related to your usage. We use cookies to collect such data from the devices you use to access our services, such as computers.

Information from Third Parties:

We may receive information about you from third parties, including:

  • Employers
  • Credit reference agencies (which may search the electoral register)
  • Fraud prevention agencies or other organizations when you apply for an account or any other product or service, or at any other time you or they provide us with such information
  • Intermediaries
  • Estate agents
  • Public sources, such as the Companies House and the Land Registry
  • Government and law enforcement authorities, such as HM Revenue & Customs

We may share or disclose your personal information to third parties for legitimate business purposes, in accordance with applicable law. This may include disclosure to:

  • You, and if necessary, your family, colleagues, and representatives
  • HM Revenue & Customs
  • Our regulators and other competent authorities
  • Statutory bodies
  • Credit reference agencies
  • Fraud and crime prevention agencies
  • Introducers and intermediaries who referred you to us
  • Companies or individuals you ask us to share your information with
  • The Direct Debit scheme, if you authorize a direct debit from your account with us
  • Other lenders holding a charge over your property, if you have a loan or mortgage with us secured by the same property
  • Any third party to whom we transfer or may transfer our rights and obligations as part of a restructuring, sale, or acquisition—provided that your information is used only for the same purposes for which it was originally collected and/or used by us
  • Account information service providers or payment initiation service providers that you have authorized

We may also disclose your information if we are required to do so—such as to any relevant party for the purpose of preventing, investigating, detecting, or prosecuting financial crime, or where the law otherwise permits.

We will only share your information with third parties who agree to ensure its security and confidentiality.

Joint Accounts

If you open a joint account, this means your personal information will be shared with the other applicant. For example, both account holders will be able to view all transactions.

Transfer of Personal Information Abroad

If we transfer your personal data to any person, office, branch, or organization, we will ensure they agree to uphold the same levels of protection, comply with applicable legal requirements, and use your data strictly in accordance with our instructions.

We will transfer your personal data outside the country if:

  • You have given your explicit consent to the transfer
  • The transfer is necessary for the performance of a contract between you and the Bank, or to take steps at your request before entering into a contract
  • The transfer is required by law
  • The transfer is necessary to protect your vital interests or those of another person when you are physically or legally incapable of giving consent

When transferring your personal data abroad, we will protect it in accordance with applicable legal requirements by using one of the following safeguards:

  • Transferring it to a country with data protection laws that offer equivalent protection
  • Ensuring a legally binding agreement is in place between the Bank and the data recipient that requires the same level of data protection

Fraud prevention agencies (FPAs) may also transfer your data to other countries. In such cases, they will ensure there is a legally binding contract in place that requires the recipient to protect the data to the same standard as required under applicable law.

Automated Decisions and Your Personal Information

The Bank does not use your personal data to make fully automated decisions involving profiling. However, we use third-party services that may employ automated decision-making for identity verification purposes during the account opening process.

You have the right to object to such automated decisions and request that a human reviews the outcome.

Some of the personal data we hold or are permitted to receive from others may be used to assist in our decision-making processes. For example:

Account Opening:

The Bank will use the information you provide to ensure the product or service is appropriate and meets the necessary criteria for account opening.

Fraud Detection

The Bank has systems and controls in place to prevent fraud, money laundering, and the financing of terrorism. We may use your personal information to determine whether your account is being used for such purposes.

If we believe that an account is being used to facilitate such activities, we may block the account and deny access.

Credit Reference Agencies

We may use credit reference agencies for both potential and existing clients of the Bank. We carry out identity checks when you apply for a product or service—whether for yourself or your business. If we are unable to verify your identity through this process, we may request physical identification documents and contact you accordingly.

We may share your personal information with credit reference agencies, and they may provide us with information about you, including:

  • Personal details such as your name, address, and date of birth
  • Credit status
  • Details of any credit arrangements you may have with a joint account holder
  • Financial history and data
  • Public information such as data from the electoral register or Companies House

This information may be used for the following purposes:

  • To verify application details and fulfill regulatory requirements by fully identifying our customers
  • To prevent fraud, financial crime, and terrorism-related offences
  • To recover debts owed to the Bank
  • To verify the details of applicants and employees

Information about you may already be associated with records related to your partner or family members, where a financial “association” has been established. Any searches we make with credit reference agencies may be assessed with reference to any such “linked” records.

Another person’s record may be “linked” to yours if:

  • You apply jointly for a product or service
  • You inform us of a financial connection with another person
  • The credit reference agencies already have existing associated records

This “association” will be considered in future applications made by either or both of you until one of you successfully files a “disassociation” request with the credit reference agencies.