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 Birmingham Midshires, 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.
(b) 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 (including the creation of profiles used to uniquely identify you when you use our online, mobile and telephony services) which are used to help us combat fraud and other illegal activity; and
(c) information Lloyds Banking Group companies receive from each other, from or through other organisations (for example card associations, credit reference agencies, insurance companies, retailers, comparison website, social networks, and fraud prevention agencies) whether in the course of providing products and services to you or otherwise, and from information we gather from your use of and interaction with our internet and mobile banking services and the devices you use to access them.
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:
- 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;
- facilitating the secure access to online platforms
and also for the following data sharing activities:
- 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.
By sharing this information it enables us, and other companies in the Lloyds Banking Group, to better understand your needs and run your accounts in the efficient way that you expect.
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:
- 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).
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.
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.
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.
Please contact us on 0345 602 2828 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.
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:
PO Box 81
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 09 September 2013.