Using personal information

How we use personal information

We will use your information, including relevant Sensitive data, for:

• Processing your enquiry/application
• Providing an illustration
• Opening and administering accounts & services you have with us
• Contacting you when necessary
• Fraud prevention and detection
• Legal and regulatory compliance
• Marketing (unless you opt out)
• Market research
• General business purposes
• Contacting a licensed credit reference agency
• Checking identity and validity of information provided

General use of your personal information

• We may, where necessary, pass your details to third party organisations so they can provide a quote, administer a product/claim or undertake processing on our behalf, e.g. mailing houses. We will only do this with your consent or unless we are obliged by law and this will only be with a contract that protects your information.
• The details of how we use your personal information are explained, and your consent is obtained, when you make an application on the relevant pages of our website or on application forms if you are applying in a branch.
• Unless you have indicated that you do not want to be contacted for marketing purposes, we will assume that we may use any of the contact details which you have given us to communicate with you.
• We will keep your personal information only for as long as necessary. If you are merely making an enquiry and do not open an account with us, we will only keep your details for 36 months.
• If you are making an enquiry or application on behalf of another person, you must have their authority to act on their behalf, to give us their personal information, to authorise a credit search if necessary and to consent to the use of their personal information by us.
• If we use an automated system to make a decision about you, such as credit scoring, we will tell you if your application is rejected and give you the opportunity to discuss the matter with us. The decision will be reviewed and may be changed, if appropriate.
• In the course of managing your account(s), we may also disclose personal information to our external auditors and relevant regulatory bodies, associate companies' agents, and service providers. Check the other disclosures section for more details.
• For certain applications we pass your personal information to licensed credit reference agencies and fraud prevention agencies. More details are provided for each application.
• Any document provided during or after the application process to help prove identity may be checked with the issuing authority.
• If you supply false or inaccurate information or we have reason to suspect you of fraud or money laundering, we may contact and disclose information to the police or the National Criminal Intelligence Service.
• To improve the quality of our service, all communications with us may be monitored or recorded for staff training and for your protection and security.
• CCTV is in operation in some of our offices. The images are used for crime prevention and public safety.

Other disclosures

We may disclose personal information to

• Our external auditors and regulatory bodies including the Financial Ombudsman Service and the Financial Services Authority, and
• Associate companies, agents and service providers, including solicitors and valuers acting for the Society, debt recovery agents, letting agents, market research agencies and providers of information technology services.

General business purposes

General business purposes for which we process personal information include verifying your identity, updating customer records, handling customer queries and complaints, statistical analysis, including analysis of customer preferences, devising new products and computer system testing.

Sensitive data

Sensitive Personal Information is defined in the Data Protection Act as information relating to:

• Racial and ethnic origin
• Political opinions
• Religious or similar beliefs
• Trade union membership
• Physical or mental health
• Sexual life
• Commission or alleged commission of offences and related proceeding and sentences

We only use sensitive information where it is necessary for the service you have requested or for our other business activities, for example health details for life insurance and criminal offences for fraud prevention.

We do hold details such as your title, gender and country of origin from which such things as religion, sex and race may be inferred, but we will always treat it with care.

Credit references

• We may undertake a search with Credit References Agencies for the purposes of verifying identity and the details submitted, in line with regulatory requirements. The Credit References Agencies may check the details supplied against any database (public or otherwise) to which they have access. They may also use the details in the future to assist other companies for verification purposes. A record of the search will be retained, but will not affect future credit. By proceeding with an application you are agreeing to a search being undertaken in this way.
• We use the following credit reference agencies for credit searches and identity checks:

  Experian	Equifax
  Consumer Help Service Experian P.O. Box 8000 Nottingham NG1 5GX www.experian.com	Credit File Advice Centre Equifax P.O. Box 1140 Bradford BD1 5US www.equifax.com

• You have the right to apply directly to them for details of information, which they hold about you, subject to payment of a fee, currently £2. You should ensure that your letter includes:
  • Your full name: Title, Forename, 2nd Initial, Surname (and maiden name, if appropriate)
  • Details of all addresses you have lived at over the last 6 years - including town, county, postcode and date moved in
  • A cheque, payable to either Equifax or Experian, for £2.00
  • The date and your signature to authorise the Credit File request.

Implications of a credit search carried out for mortgage applications

Whether or not your application to us is successful, each agency will add details of the search and your application to their records. This information will be shared with other lenders and grantors of credit and insurance who will use it when assessing any applications for banking, loan, hire facilities or insurance, which you or a member of your household may make in future. They will use it for fraud prevention, debt recovery and tracing debtors. The agencies may also use the information for statistical analysis and market research.

Fraud Prevention

The fraud prevention agencies we use include:

• National Hunter
• CIFAS

If false or inaccurate information is provided and fraud or money laundering is identified, details will be passed to fraud prevention agencies and/or Law enforcement 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, 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.

We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.