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How your personal information is used by Lloyds Banking Group Companies
Last updated September 2013
Your information will be held by Bank of Scotland plc which trades as St James’s Place Bank, part of the Lloyds Banking Group.
More information on the Group can be found at www.lloydsbankinggroup.com.
Where we obtain your information
Your personal information will be held securely in Lloyds Banking Group systems so that we and any other companies in our Group that you have dealings with, either now or in the future, can manage your relationship with us. This will include information you provide when you apply to us, and any additional information provided by you or others in various ways, including:
(a) in applications, emails and letters, during telephone calls and conversations in branch, when registering for services, in customer surveys, when you participate in competitions and promotions, through Lloyds Banking Group company websites, and during financial reviews and interviews.
We will not retain your personal information for longer than is necessary for the maintenance of your account, or for legal or regulatory requirements.
How we share your information
We may share the personal information we hold about you across the Lloyds Banking Group for the following administrative activities:
Your data may also be used for other purposes for which you give your specific permission, or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.
When we may share your information
We will treat your personal information as private and confidential, but may share it with each other and disclose it outside the Lloyds Banking Group if:
(a) allowed by this agreement;
We will always ensure your information remains safe and secure.
Using your information to help prevent terrorism and crime
The Government also requires us to screen applications that are made to us to ensure we are complying with the international fight against terrorism and other criminal activities. As a result of this we may need to disclose information to government bodies.
Sharing your information to assist with asset buying or selling
Lloyds Banking Group companies may in the future wish to sell, transfer or merge part or all of their business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it. If so, they may disclose your personal information to a potential buyer, transferee, or merger partner or seller and their advisers so long as they agree to keep it confidential and to use it only to consider the possible transaction. If the transaction goes ahead, the buyers, transferee or merger partner may use or disclose your personal information in the same way as set out in this notice.
Sharing your personal information with credit card providers
If you hold a credit or debit card with us, we will share transaction details with our scheme providers (e.g. Visa or Mastercard).
Searching insurance records
If you apply to us for insurance, we will pass your details to the insurer. If you make a claim, any information you give to us, or to the insurer, may be put onto a register of claims and shared with other insurers to prevent fraudulent claims. A list of the participants is available from the insurer. We may also disclose your information within our group of companies, to our agents and other insurers to investigate or prevent fraud.
Sharing your personal information between 1st and 2nd charge lenders
If you have a secured loan or mortgage with us, we may need to share information with other lenders who also hold a charge on your property.
If you give personal information about someone else (such as a joint applicant) then you should not do so without their permission. Where information is provided by you about someone else, or someone discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this privacy notice.
Sometimes, when you open a joint account or product, this may mean that your personal data will be shared with the other applicant. For example, transactions made by you will be seen by your joint account holder and vice versa.
How we manage sensitive personal information
The Data Protection Act defines certain information 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. As a customer, there may be times when you give us sensitive information. We may share it with other parts of the group and our subcontractors to keep your records up to date.
How we manage information collected on credit card statements
Some transactions that you or additional card holders make on a card account may cause sensitive or confidential details to appear on your statement. By using your card to make such transactions you give us your explicit consent to process this information.
Using companies to process your information outside the EEA
All countries in the European Economic Area (EEA), which includes the UK, have similar standards of legal protection for your personal information. We may run your accounts and provide other services from centres outside the EEA (such as the USA and India) that do not have a similar standard of data protection laws to the UK. If so, we will require your personal information to be protected to at least UK standards. We may process payments through other financial institutions such as banks and the worldwide payments system operated by the SWIFT organisation if, for example, you make a CHAPS payment or a foreign payment. Those external organisations may process and store your personal information abroad and may have to disclose it to foreign authorities to help them in their fight against crime and terrorism. If these are based outside the EEA, your personal information may not be protected to standards similar to those in the UK.
Using credit scoring
When you apply for credit, an automated system known as credit scoring may be used when considering whether to agree the borrowing. It is a method of assessing your likely conduct of an account based on a range of data, including the conduct of previous similar accounts. It is a system widely used by credit providers to help make fair and informed decisions on lending.
The credit scoring methods used are regularly tested to ensure they remain fair, effective and unbiased. Using a credit scoring system helps our Group companies to lend responsibly. If you submit an application and it is declined through this automated process, you can contact us within 21 days to have the decision reconsidered. You also have the right to ask that the decision is not made based solely using a credit scoring system.
How we use Credit Reference Agencies
Credit Reference Agencies (CRAs) collect and maintain information about consumers' and businesses' credit behaviour. This includes Electoral Register, fraud prevention, and credit information - including details of previous applications and the conduct of your accounts - and public information such as County Court Judgements, decrees, and bankruptcies.
The information that Lloyds Banking Group companies and other organisations provide to credit reference agencies about you, your financial associates and your business (if you have one) may be provided to other organisations and used by them and us to:
(a) help make decisions, for example when:
If a Lloyds Banking Group company needs to make a credit decision when you apply for a credit-based product or service (e.g. mortgage, personal loan, credit card, or current account) or to review the amount of credit it provides under an existing agreement, such as an overdraft, your records will be searched, along with those of anyone who is financially associated with you such as your spouse or partner. The CRA will keep a record of this search and place a "footprint" on your credit file, whether or not the application proceeds.
We may give details of your account and how you conduct it to credit reference agencies, including if you borrow and do not repay in full and on time. If you fall behind with your payments and a full payment or satisfactory proposals are not received within 28 days of a formal demand being issued, then a default notice may be recorded with the CRAs. Similar information may also be given about your other lending/credit relationships with members of the group. Any records shared with CRAs will remain on file for 6 years after your account is closed, whether it has been settled by you or as a result of a default. Other organisations may see these searches and updates if you apply for credit in the future, and these may affect your ability to borrow from other lenders.
If you apply for or hold an account in joint names, or tell us that you have a spouse or financial associate, a financial association will be created between your records, including any previous and subsequent names used by you. This means that your financial affairs may be treated as affecting each other. These links will remain on your and their files until such time as you or your partner is successful in applying for a disassociation with the CRAs to break that link. You must be sure that you have their agreement to disclose information about them. Searches may be made on all joint applicants, and search footprints will be left on all applicants’ records.
You have a right to apply to the credit reference agencies for a copy of your file.
Using Fraud Prevention Agencies
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 will share your personal information from your application with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
Please contact us on 0845 602 7174 if you want to receive details of the relevant fraud prevention agencies. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
How we check your identity
We may ask you to provide physical forms of identity verification when you open your account. Alternatively, we may search credit reference agency files in assessing your application. The agency also gives us other details and information from the Electoral Register to verify your identity. The agency keeps a record of our search, whether or not your application proceeds. Our search is not seen or used by lenders to assess your ability to obtain credit.
Undertaking Anti-Money Laundering checks
To comply with money laundering regulations, there are times when we need to confirm (or reconfirm) the name and address of our customers. This information may be shared with other group companies.
Obtaining information about you, and other personal details
When you apply for a mortgage or further borrowing it may be necessary to obtain references, details of your existing financial commitments, and any other information that is required to assess or review lending risks, to recover debts, and to prevent or detect fraud. Where applicable, your current and previous employers, accountant, landlord, lender, bank, insurance or pension company may be contacted to obtain this information. In limited circumstances these references may need to be obtained after you open your account. This may be for regulatory purposes, or if the lending decision needs to be reviewed. Your permission to obtain these references will therefore continue to apply after your account has been opened. It may also be necessary to obtain information or documentation from your solicitor relating to any work they carry out either on your or our behalf.
Using your details for service contact
Making sure we deliver excellent customer service is very important to us and to do this various methods of communication may be used when sending you information about your account. Most of the time you will be contacted by letter or telephone, but you may also be sent updates by text message or email when it is believed to be appropriate. You can ask us to stop sending these messages at any time. Additionally, in extraordinary circumstances (such as natural disaster or civil unrest) we may also send you updates by text message or email. If we decide to use email to contact you, we will only do this if we have ensured that using email will not put your information at risk, or, if you have requested we email you, that we have explained the risks of sending an "insecure" email and that you are happy to accept that risk.
In addition you may wish to choose a channel of communication that suits you when you need to contact us. If you need to email a Lloyds Banking Group company, we recommend you check their website to see if a secure email facility exists so that your email can be sent securely. If you send us emails in other ways, such as from your personal account, then remember that the message may not be secure and there is a risk that it could be intercepted. If you choose to send an "insecure" email, please keep the amount of confidential information you include to a minimum.
Recording phone calls
We may monitor or record phone calls with you in case we need to check we have carried out your instructions correctly, to resolve queries or issues, for regulatory purposes, to help improve our quality of service, and to help detect or prevent fraud or other crimes. Conversations may also be monitored for staff training purposes.
Using information on social networking sites
As part of our ongoing commitment to understanding our customers better, we may research comments and opinions made public on social networking sites such as Twitter and Facebook.
Obtaining a copy of your information
Under the Data Protection Act you have the right of access to your personal data. 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. For further details on how to request a copy of your information, please write to the:
St James's Place Bank
Using your personal information to contact you about products and services.
Unless you have asked us not to, we and other Lloyds Banking Group companies may contact you by mail, telephone, email or text message about products and services available from the Group. In addition we may also contact you about products and services from selected companies outside the Group, which we believe may be of interest to you or benefit you financially.
We promise not to contact you about everything - only if we think it could be appropriate and relevant to you, such as preferential savings opportunities, account upgrades or special offers. This contact may continue after your relationship with us ends. You may opt out of receiving this information at any time by calling us, writing to us or contacting your local branch.
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.
In general, you can visit Lloyds Banking Group websites without identifying who you are or revealing any information about yourself. However, cookies are used to store small amounts of information on your computer, which allows certain information from your web browser to be collected. Cookies are widely used on the internet and do not identify the individual using the computer, just the computer being used. Cookies and other similar technology make it easier for you to log on to and use our websites during future visits.
Changes to our Privacy Notices
We keep our privacy notice under regular review and we will reflect any updates within this notice. This notice was last updated 9 September 2013.