- Looking after your information The Data Protection Act requires Lloyds Banking Group companies to manage personal information in accordance with the Data Protection Principles. In particular, our Group of companies is required to process your personal information 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 in order that we may provide the product or service that you require. All our employees are personally responsible for maintaining customer confidentiality. We provide training and education to all employees to remind them about their obligations. In addition, our policies and procedures are regularly audited and reviewed.
- Who we are Your information will be held by St Andrews Group plc which is part of the Lloyds Banking Group.
- Our Group The Lloyds Banking Group includes us and a number of other companies using brands including Lloyds TSB, Halifax and Bank of Scotland, and their associated companies. 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:
- 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.
- from analysis (for example, the amount frequency, location, origin, and recipient) of your payments and other transactions, and your use of services involving other Lloyds Banking Group companies and what they know from operating your account; and
- information Lloyds Banking Group companies receive from each other, from our business partners, and from other organisations such as credit reference agencies and fraud prevention agencies.
- 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:
- providing you with products and services and notifying you about either important changes or developments to the features and operation of those products and services;
- responding to your enquiries and complaints;
- administering offers, competitions, and promotions;
- undertaking financial reviews;
- updating, consolidating, and improving the accuracy of our records;
- undertaking transactional analysis;
- arrears and debt recovery activities;
- testing new systems and checking upgrades to existing systems;
- crime detection, prevention, and prosecution;
- evaluating the effectiveness of marketing, and for market research and training;
- customer modelling, statistical and trend analysis, with the aim of developing and improving products and services;
- assessing lending and insurance risks across the Lloyds Banking Group;
- managing your relationship with the Lloyds Banking Group companies.
- 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:
- allowed by this agreement;
- you consent;
- needed by our agents, advisers or others involved in running accounts and services for you or collecting what you owe Group companies;
- needed by subcontractors to help us manage your records;
- HM Revenue & Customs or other authorities require it;
- the law, regulatory bodies, or the public interest permits or requires it;
- required by us or others to investigate or prevent crime;
- needed by market research companies to assist us in providing better products and services for you; or
- to any other parties connected with your account (including guarantors).
- required as part of our duty to protect your accounts, for example we are required to disclose your information to the UK Financial Services Compensation Scheme (FSCS).
- 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)
- Joint Applicants 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.
- Sharing personal information between joint applicants 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.
- 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 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:
- Checking details on applications for credit and credit related or other facilities.
- Managing credit and credit related accounts or facilities.
- Recovering debt.
- Checking details on proposals and claims for all types of insurance.
- Checking details of job applicants and employees.
- 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.
- 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 to keep you updated about your account. Most of the time we communicate by telephone or post, but we recognise that E mail is becoming a more popular process. If we decide to use E mail to contact you, we will only do this if we have ensured that using E mail will not put your information at risk, or, if you have requested we E mail you, that we have explained the risks of sending an "insecure" E mail 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 E mail a Lloyds Banking Group company, we recommend you check their website to see if a secure E mail facility exists so that your E mail can be sent securely. If you send us E mails 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" E mail, please keep the amount of confidential information you include to a minimum. 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 when we consider it to be appropriate.
- 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 contact Data Subject Access Request Department, Customer care, Tredegar Park, Newport, South Wales. NP10 8SB.
- 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.
You may opt out of receiving this information by calling us, writing to us or contacting your local branch.
- Passing your information to other companies for their own direct marketing 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.
- Using cookies 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.
To access our cookie notice, please go to http://www.st-andrews.co.uk/information/cookies.
Changes to Privacy Notice,We keep our privacy notice under regular review and we will reflect any updates within this notice. This privacy notice was last updated on 1st October 2012.
St Andrew's Group
Claims Management Department
PO Box 534