Data Protection Privacy Notice

Personal data we process may include:

• Your title, full name, your contact details, including for instance your email address, home and mobile telephone numbers;
• Your home address, correspondence address (if different) and recent address history;
• Your date of birth
• Your nationality, if this is necessary for us to comply with our legal and regulatory requirements;
• Records of how you have contacted us and, if you get in touch with us online, details such as your mobile phone location data, IP address and MAC address;
• Some special categories of personal data such as about your health or if you are a vulnerable customer (more details below).
• Details of account(s) held with other providers if you pay into your savings product from those other account(s);
• Where a person other than the savings account holder makes a withdrawal from the account, information about that person and the transaction; and
• Information about your tax position.

If you make a joint application, for example with your spouse, partner, or family member, please share this privacy notice with them, as we will also collect their personal data as described above. If you look now at the “What are the lawful bases” 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 data.  We may ask you to obtain consent from the joint applicant.

If there is somebody who has power of attorney over your affairs, that person will receive a copy of our privacy notice when we make contact with him/her directly.

We will generally collect your personal data from you directly.

In addition, we obtain your personal data from other sources such as a Credit Reference Agency, publicly available directories and information (eg telephone directory, social media, internet, news articles), other organisations to assist in prevention and detection of crime, police and law enforcement agencies.

Some of the personal data obtained from the Credit Reference Agency 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 data that we process some of the CRAs’ other sources of information (which are our own source of information too).

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

1. Processing necessary to perform our contract with you or for taking steps prior to entering into it:

1.1 Administering and managing your savings account, updating your records, tracing your whereabouts to contact you about your account;

1.2 All stages and activities relevant to managing your savings account including enquiry, application, administration and management of accounts; and

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

2.1 Administering and managing your savings account and services relating to that, updating your records, tracing your whereabouts to contact you about your account;

2.2 To test the performance of our products, services and internal processes;

2.3 To adhere to guidance and best practice under the regimes of governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, the Ombudsman, the Information Commissioner’s Office and under the Financial Services Compensation Scheme;

2.4 For management and audit of our business operations including accounting;

2.5 To carry out searches at Credit Reference Agencies (CRAs) pre-application, at the application stage, and periodically after that.

2.6 To carry out monitoring and to keep records (see below);

2.7 To administer our good governance requirements, such as internal reporting and compliance obligations or administration required for AGM processes;

2.8 For market research and analysis and developing statistics;

2.9 For marketing communications from BIBS only, and only where we believe the information may be of interest to you. If you do not wish to receive marketing please let us know.

2.10 When we share your personal information with these other 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 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;
• Our legal and other professional advisers, auditors and actuaries;
• Financial institutions and trade associations;
• Governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, the Ombudsman, the Information Commissioner’s Office and under the Financial Services Compensation Scheme;
• Tax authorities who are overseas for instance if you are subject to tax in another jurisdiction we may share your personal information directly with relevant tax authorities overseas (instead of via HMRC);
• 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;
• CRAs (see below where we explain more); and

3. Processing necessary to comply with our legal obligations:

3.1 For compliance with laws that apply to us;

3.2 For establishment, defence and enforcement of our legal rights;

3.3 For activities relating to the prevention, detection and investigation of crime;

3.4 To carry out identity checks and anti-money laundering checks, pre-application, at the application stage, and periodically after that.

3.5 To carry out monitoring and to keep records (see below);

3.6 To deal with requests from you to exercise your rights under data protection laws;

3.7 To process data about a crime or offence and proceedings related to that (in practice this will be relevant if we know or suspect fraud); and

3.8 When we share your personal data 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;
• Law enforcement agencies and governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, the Ombudsman, 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, to protect vital interests and to protect the security or integrity of our business operations.

4. Processing with your consent:

4.1 When you request that we share your personal data with someone else and consent to that;

4.2 For direct marketing communications;

4.3 For some of our processing of special categories of personal data such as about 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).

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:

5.1 Processing of your special categories of personal data such as about your health or if you are a vulnerable customer.

5.2 Processing that we need to do to fulfil our legal obligations and regulatory requirements.

5.3 When we share your personal data with other people and organisations if they need to know that you are a vulnerable customer and your relatives, social services, your carer, the person who has power of attorney over your affairs.

Much of what we do with your personal data is not based on your consent, instead it is based on other lawful bases.  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 using the details above.  The consequence might be that we cannot send you some marketing communications or that we cannot take into account special categories of personal data such as about 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 are based in the UK and do not normally transfer personal data outside the UK, however we may use suppliers who may transfer data to, or store data in, locations both inside and outside the UK. We also share some personal data with Credit Reference Agencies as well as Money Laundering Prevention Services and Fraud Prevention Agencies who may have operations both inside and outside of the UK.  Whenever information is sent to locations outside of the UK, we will ensure that there are suitable safeguards to protect it.

In order to process your application, we will perform identity checks on you with one or more Credit Reference Agencies (CRAs).

To do this, we will supply your personal data to them and they will give us information about you. This will include information such as your name, address, date of birth. 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:

• Verify the accuracy of the information you have provided to us;
• Prevent criminal activity, fraud and money laundering;
• Manage your account(s);

We will continue to exchange information about you with CRAs while you have a relationship with us.

If you are making a joint application we will link your records together, so you should make sure you discuss this with any other applicants, 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 for a disassociation with the CRAs to break that link.

The personal data we collect from you may be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance or employment. For more information see Data Privacy Notices from other organisations below. 

You should tell us without delay so that we can update our records. You can do this by emailing savings@bibs.co.uk or by writing to our Head Office.

We are unable to provide you with the savings product or to process your application without having personal data about you.  Your personal data is required before you can enter into the relevant contract with us, or it is required during the life of that contract, or it is required by laws that apply to us.  If we already hold some of the personal data that we need – for instance if you are already a customer – we may not need to collect it again when you make your application.

In cases where providing some personal data is optional, we will make this clear.

In this section monitoring means any listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person face to face meetings and other communications.

We may monitor where permitted by law and we will do this where the law requires it.  Also, 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, 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.

We may conduct short term carefully controlled monitoring of your activities on your savings account 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.

Telephone calls between us and you in connection with your application and the savings product may be recorded to make sure that we have a record of what has been discussed and what your instructions are.  We may also record these types of calls for the quality control and staff training purposes.

Unless we explain otherwise to you, we will hold your personal data for the following periods:

• Retention in case of queries. We will retain the personal data that we need to keep in case of queries from you (for instance, if you apply unsuccessfully for a product or service) for 1 year unless we have to keep it for a longer period (see directly below);
• Retention in accordance with legal and regulatory requirements. We will retain the personal data that we need to keep even after the relevant contract you have with us has come to an end for 6 years and this will be to satisfy our legal and regulatory requirements; and
• Retention in case of claims. We will retain the personal data that we need to keep for the period in which you might legally bring claims against us which in practice means 6 years after your account is closed, unless we have to keep it for a longer period (see directly below)

If you would like further information about our data retention practices, contact us.

Here is a list of the rights that all individuals have under data protection laws.  They do not apply in all circumstances.  If you wish to exercise any of them we will explain at that time if they are engaged or not.

• The right to be informed about your processing of your personal data;
• The right to have your personal data corrected if it is inaccurate and to have incomplete personal data completed;
• The right to object to processing of your personal data;
• The right to restrict processing of your personal data;
• The right to have your personal data erased (the “right to be forgotten”);
• The right to request access to your personal data and to obtain information about how we process it;
• The right to move, copy or transfer your personal data (“data portability”);
• Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.

You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/.

If you wish to exercise any of these rights with Credit Reference Agencies, Fraud Prevention Agencies or Money Laundering Prevention Services, you should contact them directly.

Your personal data may be converted into statistical or aggregated data which cannot be used to re-identify you.  It may then be used to produce statistical research and reports. This aggregated data may be shared and used in all the ways described in this privacy notice.

We may use your home address, phone numbers, email address to contact you according to your marketing preferences.  This means we do this only if we have a lawful basis which allows it under data protection laws – see above for what our lawful basis for marketing is. You can stop our marketing at any time by emailing marketing@bibs.co.uk or writing to our Head Office or by following the instructions on how to do that in the marketing email or other communication.

We have mentioned that we share your personal data with Credit Reference Agencies, Money Laundering Prevention Services and Fraud Prevention Agencies. Further information and the relevant Privacy Notices are available on request.

The identities of the CRAs, their role as fraud prevention agencies, the data they hold, the ways in which they use and share personal data, data retention periods and your data protection rights with the CRAs are explained in more detail at https://ico.org.uk/your-data-matters/. A Credit Reference Agency Information Notice (CRAIN) is also accessible from each of the three CRAs – following any of these three links will also take you to the same CRAIN document:

TransUnion

Equifax

Experian