Loans privacy and security
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- A service of quality
- Confidentiality
- Providing the service for which you have applied
- Keeping you informed
- Research and statistical analysis
- Cookies and how we use them
- Protecting our customers
- Anti-money laundering and statutory obligations
- Introducers and affinity partners
- Sensitive data
- The details we hold
- Credit reference agencies' addresses
- Security
- For our business customer
- Other information
A Service of quality
We (esure, Bank of Scotland, Halifax and HBOS plc Group companies) place paramount importance on customer service and aim to meet your expectations on every occasion. To achieve this aim we need accurate personal information about you. Please help us take prompt and efficient action by informing us of any changes to your personal circumstances by writing to us. We have a legal obligation under the Data Protection Act to ensure that all information held and processed about you complies with the principles of the Act.
The Act requires all personal information to be treated in the strictest confidence and to be used only for purposes of which you are aware. Our complaint handling procedures meet the standards required by the Financial Services Authority. A copy of these procedures is available on request.
Confidentiality
We will treat all your personal information as private and confidential (even when you are no longer a customer). Nothing about your accounts nor your name and address will be disclosed to anyone, other than in four exceptional cases permitted by law. These are:
- where we are legally compelled to do so;
- where there is a duty to the public to disclose;
- where disclosure is required to protect our interest (This will not be used as a reason for disclosing information about you or your accounts, including your name and address, to anyone else for marketing purposes.)
- where disclosure is made at your request or with your consent (This can be either as a result of an application for a product or service or by signing an explicit declaration as part of the application. Consent does not need to be in writing if the service is provided over the telephone.)
From time to time we will employ agents and sub-contractors to process your information on our behalf. The same duty of confidentiality and security will apply to our agents and sub-contractors and all processing will only be carried out under our instruction and will be supported by written contract. Sometimes, these companies may be located abroad in countries that do not have data protection laws. In these circumstances, we always take great care to ensure that your personal information is kept safe and secure.
Providing the service for which you have applied
Your details will be used in providing the service you applied for and for the ongoing administration of the service. If you are taking out insurance, your details will be passed to the insurers for this purpose. If you make a claim, any information you provide to the insurers may be put onto a register of claims through which insurers share such information to prevent fraudulent claims. A list of the participants and the address of the operator are available from the insurers.
Keeping you informed
We (esure, Bank of Scotland, Halifax and HBOS plc Group companies) may use your information to contact you by mail, phone or e-mail to inform you of other relevant products or services offered by us or selected third parties. We may use information we obtain from your account transactions in this decision-making process. We may use your account details, transactions and information provided to us by third parties in our customer contact programme. We will only contact you by fax or e-mail where you have given us your consent. These companies may also use your information for research, statistical analysis and administration purposes. You are, of course, under no obligation to apply for any of the services or products offered. If you prefer not to receive any of this information from esure, please write to us at Data Unit, esure, Freepost NWW15306, City House, City Road, Chester CH88 3YZ.
Research & statistical analysis
We will use your details to assist us in understanding individual needs and business trends in order to improve the products and services we offer.
Cookies and how we use them
A cookie is a small piece of information, which websites that you visit place into your Internet browser, and can retrieve later. Cookies cannot be read by any website other than that which originally placed the cookie. We do not store any personal or traceable customer information in the cookies that we use. Additionally, all our cookie data is encrypted to prevent third parties from accessing the information they contain. Some cookies last only as long as you are browsing a particular website and are deleted when you move on to another website. Other cookies are stored by your browser and are retrieved by the website when you visit it again. Typically, this type of cookie could deliver a personalised welcome message to a customer. Our websites use cookies for tracking purposes. Cookies allow us to track which banner advertisements on external sites have led customers to our service. They also help to manage the rotation of advertisements that appear on your browser, preventing you from getting the same advert more than once. It is possible to disable the cookies when using this website, as this should cause no degradation of the content you can access or functionality you can use. If you want to delete any Cookies that are already on your computer, please refer to the instructions for your file management software to find the file or directory that stores cookies. If you want to stop cookies being stored on your computer in future, please refer to your browser manufacturer's instructions by clicking 'Help' in your browser menu. Further information on deleting or controlling cookies is available at www.aboutcookies.org. Our service uses Microsoft Active Service Pages (ASP), which need cookies to operate properly. It is important that your Internet browser is set to accept cookies when using our online service, otherwise you will not be able to use the site to the full. Cookies help you navigate around the site and fill in forms. Cookies also enable us to provide you with informational messages and to ensure your transactions are secure.
Protecting our customers
We always try to protect you from entering into any agreement that may not be in your best interest. When you apply for credit we may use a process known as Credit Scoring. This will help us to assess your application and verify your identity to ensure that you are able to re-pay the borrowing comfortably and fulfils our duty to you as a responsible lender. Declined applications based on this automated technique can be reviewed manually on request.
In considering an application we may search credit reference agency files for credit information in assessing your application. The agency also gives us other details and information from the Electoral Register to verify your identity. The agency will keep a record of the search type (credit or identification), whether or not your application proceeds.
Members of our group and other companies may use credit searches and other information supplied to us and/or the credit reference agencies about you and someone linked financially with you, to make credit decisions about you or other members of your household. Any of this information may also be used for identification purposes, debt tracing, preventing money laundering and managing your account. Associations linking your financial records may be created on Credit Reference Agency records when you apply for accounts in joint names. Your financial records and those of anyone financially associated with you, may be considered in any future applications you make.
We will also add to your record with the Credit Reference Agencies details of your agreement with us, the payments you make under it, any default or failure to keep to its terms and any change of address you fail to tell us about where a payment is overdue. It is important that you give us accurate information. We will check your details with fraud prevention agencies and if you give us false or inaccurate information and we suspect fraud, we will record this.
We and other organisations may use and search these records to:
- help make decisions about credit and credit related services for you and members of your household;
- help make decisions on motor, household, credit, life and other insurance proposals and insurance claims, for you and members of your household;
- trace debtors, recover debt, prevent fraud, and to manage your accounts or insurance policies;
- check your identity to prevent money laundering, unless you furnish us with other satisfactory proof of identity.
(If you want to receive details of the fraud prevention agencies from whom we obtain and with whom we record information about you, please call our Fraud Helpline on 01244 692219.) For these purposes we or they may make further searches. The Credit Reference Agencies and fraud prevention agencies will also use the records for statistical analysis about credit and about insurance and fraud.
If this application is in your sole name, information held about you by credit reference and fraud prevention agencies may be linked to records relating to any partner or partners of you. For the purpose of this application you may be treated as financially linked and your application assessed with reference to any 'associated' records. If this is a joint application, an 'association' will be created at credit reference and fraud prevention agencies which will link your financial records until one of you successfully files a 'disassociation' at the credit reference or fraud prevention agencies.
If you have experienced problems obtaining credit we recommend you request a copy of your credit file from the Credit Reference Agencies. They will charge for this service. Their addresses are shown below.
Anti-Money laundering and statutory obligations
To comply with money laundering regulations, and to help stop criminals using financial products or services to launder money, there are times when we need to confirm (or reconfirm) the name and address of our customers. We may need to do this whether you are applying to be a new customer or have been one for some time. This information may be shared with other HBOS plc Group companies. For more details about identity checks on account opening, please call 0845 123 8592 to ask for our leaflet "Your identity-how to help us prevent crime". Some Acts of Parliament oblige us to disclose information about our customers to certain bodies with statutory powers. For example, we must give information to authorised benefit fraud investigators where fraudulent benefit claims are suspected. In addition, the Inland Revenue has the statutory authority to audit our customers accounts from time to time.
If you email us, or give us your email address, we will keep a record of it.. We will not give your email address to any unauthorised third parties. When emailing us, always use the email facility on our website to make sure that the content of your email is secure. If you send us email in other ways, remember that it will be insecure and could be intercepted. If you do send us insecure email, please keep the amount of confidential information you include to a minimum. We will do likewise when we reply.
Introducers and affinity partners
If you were 'introduced' to us by a third party and/or have a relationship with or are supporting one of our affinity partners, we will give them your contact details and sufficient information about you to help with their accounting and administration. Introducers or affinity partners may use these details to contact you about products and services unless you have asked them not to do so.
Sensitive data
Certain information collected may be classified as sensitive and we can only use such data where we have your explicit consent. This data relates to racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences and will only be processed in order to provide the service requested.
Some transactions that you (or an additional cardholder) make on a card account may cause sensitive or confidential details to appear on your statement. If your card is used for such transactions, we believe that the details appear on your statement with your explicit consent.
The details we hold
These uses of your personal information are covered by our notification under the Data Protection Act. Under the terms of the Act, you have the right to obtain a copy of the information we hold about you, upon payment of the appropriate fee.
Please be assured that we will actively review your personal information on a regular basis to ensure it is accurate.
If you have any questions or concerns on the use of your personal information, please do not hesitate to contact us on 0845 123 8592 at any time.
Credit reference agencies' addresses
If you would like a copy of your credit file, please write to the following, enclosing a cheque or postal order for £2. You will need to tell them your full name and address(es) for the last six years.
Experian Limited
Consumer Help Service
PO Box 8000
Nottingham
NG80 7WF
Tel: 0870 241 6212
www.experian.co.uk
Equifax plc
Credit File Advice Centre
PO Box 1140
Bradford
BD1 5US
Tel : 0870 010 0583
www.equifax.co.uk
Security
Your application form will be sent to us through a 'secure session' using banking standards encryption. This is achieved with 128-bit SSL (Secure Sockets Layer), that encrypts your data which is then transmitted securely over the Internet.
For our business customer
The Data Protection Act does not apply to companies in themselves but it does extend to sole traders and partnerships. When an application is received from a business, in addition to the above information, information may be sought from credit reference agencies on the company directors and/or partners as individuals.
Other information
Information is available in large print, audio or Braille on request. Please call 0845 123 8592 for details. You may contact us using a textphone - 0845 603 1393 - or using Type Talk.
Bank of Scotland subscribes to the Banking Code. Copies are available on request. Occasionally, the Banking Code Standards Board who monitor compliance with the Banking Code, audit a sample of our customer records to assess our compliance with the Code. Whenever this happens, strict confidentiality conditions are always imposed.
The Governor and Company of the Bank of Scotland is licensed under Consumer Credit Act 1974 by the Office of Fair Trading. Further details of the Consumer Credit Public Register are available on www.oft.gov.uk.
