USE OF PERSONAL INFORMATION
We are Secure Trust Bank PLC, registered in England and Wales 541132, and regulated by the Prudential Regulation Authority and the Financial Conduct Authority. We use the trading names Secure Trust Bank, Moneyway, OneBill, V12 Retail Finance and V12 Vehicle Finance.
When we use "we" in this notice we mean us or anyone acting on our behalf. When we use "you", we mean the customer or applicant acting on their own behalf or for a business; or individuals associated with our commercial clients, partners and suppliers.
Please read this Privacy Statement carefully as it contains important information to help you understand our practices regarding any personal information that you give to us.
What information we collect
We process your personal information including:
- the personal information that you give us during an application for or purchase of any product or service from us, or that you have given to us during a previous application or as a customer;
- the personal information that we obtain about you from the broker, introducer or motor dealer who helps arrange the application for you;
- the personal information that we receive from third parties such as credit reference agencies and fraud prevention agencies (see below), companies you ask to share your 'Open Banking' information with us, or tax authorities, where we need to contact these third parties as part of your application or in servicing your account with us. For mortgage and motor finance applications, we receive information from your employer where you have provided your employment details;
- the personal information that you give us while servicing your account via our website, in writing or over the phone; and
- the personal information that you give us if you register interest in a product and/or service, request information or assistance from us or make a complaint.
What personal information we process
This personal information includes:
- your name;
- date of birth;
- address and your address history
- telephone number;
- email address;
- passport, driving licence, national identity card or fire arms licence details when you provide this as proof of identity;
- details of expenditure;
- bank details - sort code, account number;
- credit history and records relating to your partner or anyone else you are financially linked with (we receive this information from the credit reference agencies and fraud prevention agencies);
- details of your existing borrowings and loans;
- bank statements;
- insurance details of the vehicle for motor finance;
- transaction information on payments into and out of an account, and debit or credit card information;
- employment/self employment details;
- income, expenditure and taxation information;
- information regarding whether you have any dependants;
- identifiers assigned to your computer or other internet connected device including your IP address;
- information linked to your mobile telephone number;
- details about whether you own your property, rent it or live with others;
- publicly available information (for example on the internet, social media and on public registers);
- your proposed or financed vehicle details for motor finance;
- information relating to how you conduct your account and our dealings on it.
- information about unspent criminal convictions or pending prosecutions relating to any aspect of dishonesty, which may have a bearing on your future employment or the likely conduct of the account.
If you have a joint OneBill account, we collect this type of information about all parties to the account.
If you authorise a third party to act on your behalf, for example setting up a Power of Attorney for your account, we record the individual's name, date of birth, address, telephone number, email address, solvency status for Powers of Attorney, and bank details if the third party makes payments by direct debit for your account.
In the unfortunate circumstance that one of our customers passes away, we record the following details of the next of kin and any executors of the estate: name, address, telephone number, and email address.
If you make an application on behalf of a business, we will process personal information about shareholders, directors, partners and owners, including name, date of birth, address, credit history and publicly available information (for example on the internet, on social media and on public registers).
Where information fields are marked as mandatory on any application form that you complete, you will need to provide such information in order for us to continue with your application.
Special categories of Personal Data
Special categories of personal data include information about an individual's health and other categories of personal information which are closely protected (e.g. biometric data).
We do not generally process such information, unless you have voluntarily provided that information to us, for example, where you have notified us of a health issue that would mean you would be classed as a 'vulnerable customer' (i.e. if you, due to your personal circumstances or personal characteristics, are especially vulnerable to financial detriment ). You have the right to withdraw your consent for us to hold details of your vulnerability at any time by contacting us by telephone, email or in writing.
Criminal offence information is not defined as special categories of personal data, however, this information does require additional protections. Criminal offence information covers information related to convictions and offences, including alleged offences, court proceedings, and sentencing.
Where permitted by law, we process criminal offence information for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. It may involve investigating and gathering intelligence on suspected financial crimes, fraud and threats and sharing data between banks with law enforcement and regulatory bodies.
How we use your personal information
In summary, we use your personal information for the purposes of:
- servicing and internal processing (including by way of automated decision making for motor finance);
- management of our relationship with you (e.g. to develop your relationship with us);
- tracing customers and recovering debts;
- resolving queries/problems (e.g. responding to complaints or contacting you if you do not complete your application);
- training and service review (e.g. to help us enhance our services);
- developing our products and services; and
- complying with legal obligations (e.g. to prevent, investigate and prosecute crime, fraud and money laundering).
As detailed below, we process your personal information to fulfil our contract with you, where we have a legitimate interest to do so (except where it would override your interests or fundamental rights and freedoms which require the protection of personal information), where otherwise permitted by law, or to comply with applicable law and regulation.
• to request feedback or conduct research on our products and services (see 'Customer Survey' section)Legitimate interest to optimise customers' experience with us and develop our products and services
|PURPOSE||LEGAL BASIS (As set out under applicable data protection law - for more details click here)|
|Servicing and Internal Processing|
|• to provide the product or service that you applied for;||Legitimate interests to provide and manage the product or service|
|• to evaluate risk in connection with the provision of our services, in particular motor finance, including as noted in the section below 'Automated Decision Making';||To comply with legal obligations to manage and control risk;
Automated Decision Making is necessary for entering into, or the performance of a contract
|• to verify the identity of our customers and potential customers;||To comply with legal obligations in financial services regulations for prevention of money laundering|
|• to report on the performance of an account; (see 'Sharing with Credit Reference Agencies' section)||Legitimate interests to share performance information with credit reference agencies|
|• to confirm, update and improve our customer records;||To comply with legal obligations in the Data Protection regulations|
|• to assess what options are appropriate if you are in financial difficulties;||To comply with legal obligation to treat customers in financial difficulties fairly|
|• to trace customers and recover debts; (see 'Debt recovery' section)||Legitimate interests - debt recovery|
|• to respond to any queries or complaints that you raise;||To comply with legal obligations for complaint handling|
|• to prevent, investigate and prosecute crime, fraud and money laundering; (see 'For crime and fraud prevention and anti-money laundering' section)||To comply with legal obligations and legitimate interests for prevention of financial crime and money laundering|
|• to protect our legal rights and interests;||Legitimate interests to protect financial position and reputation|
|• to inform you if an application you have started is incomplete or to pre-populate any future applications where you have told us we can keep your information for this purpose;||Legitimate interests to aid customers in completing applications|
|Management of Relationship|
|• to manage, analyse, understand and develop your relationship with us, for example, to understand how often you access our services;||Legitimate interests to service customers' accounts, optimise customers' experience with us and develop our products and services|
|• to inform you about improvements to the Website;||Legitimate interests to optimise customers' experience on the Website|
|• to request feedback or conduct research on our products and services (see 'Customer Survey' section)||Legitimate interest to optimise customers' experience with us and develop our products and services|
|Training and Service Review|
|• for training purposes and to enhance or review the service we provide or have provided to you;||Legitimate interests to optimise customers' experience with us, to manage performance and develop our employees|
|Develop product and services|
|• to conduct statistical analysis and research (see 'Statistical analysis' section);||Legitimate interests to develop our products and services|
|to test scorecards and systems (see 'Testing' section)||Legitimate interests to develop our products and services|
|• for auditing purposes;||To comply with legal obligations to conduct audits|
|• if we are obliged to disclose information by reason of any law, regulation or court order;||To comply with legal obligations|
|• to transfer information to any entity which may acquire rights in us;||Legitimate interests for commercial interests|
|• to monitor access to and use of the Group's IT systems, including electronic communications and video conferencing technology;||Legitimate interests to manage and control information security risk and the risk of misconduct and to comply with legal obligations for prevention of crime.|
|• for any other purpose to which you agree.||With consent|
How we retain your information
The personal information that you provide will be retained by us in accordance with applicable laws. We take reasonable steps to destroy or anonymise personal information we hold if it is no longer needed for the purposes set out above.
Set out below are our retention periods
Type of personal information
• General personal data - this includes the categories of normal personal data, personal identity and personal financial data
7 years after account closure/end of relationship
• Special categories and criminal offence personal data may be captured if voluntarily provided to us. Criminal offence information could be disclosed to us by a third party or through screening checks.
7 years after account closure/end of relationship
• Call recordings
• Recordings of video conferencing technology
• CCTV - digital images if you visit one of our offices
How we share your information
The recipients with whom we share personal information are:
- our third party service providers who act on our instruction and need to know the information in order to provide us or you with a product or service;
- our third party service providers who act on our instruction and process information on our behalf to help run some of our business operations including email distribution, electronic signature processing, storage of customer documentation, IT services and websites, diallers and for statistical analysis;
- independent debt recovery agencies or service providers, tracing agents or investigators, solicitors or other agents for the purpose of collecting monies due or outstanding on your account;
- our partners including brokers, introducers and motor dealers we work with;
- our subsidiaries or affiliates, for the purpose of managing our customer relationships, administering our business and to provide you with information about other products and services which might be of interest to you;
- our advisors, for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
- our regulators or other relevant authorities (including the Prudential Regulation Authority, Financial Conduct Authority and Information Commissioner's Office) to comply with our legal and regulatory obligations;
- our trade bodies to comply with our legal and regulatory obligations and for our legitimate interests;
- entities who may or do acquire any rights in us for the purpose of a business sale or reorganisation;
- credit reference agencies (including TransUnion, Equifax and Experian) and fraud prevention agencies (including Cifas, Synectics Solutions and Lexis Nexis) - see sections below 'Sharing with Credit Reference Agencies', 'For crime and fraud prevention and anti-money laundering', 'Statistical analysis' and 'Testing';
- insurance providers (including Covea Insurance plc, Covea Life Limited, Cardif Pinnacle plc The Warranty Group and Call Assist ltd), in the event that you apply for or have purchased an insurance product through us, for the purposes of underwriting, processing, claim handling and fraud prevention. More information about the insurance providers and how they process personal information is available at coveainsurance.co.uk/privacy-statements-and-cookies/, www.cardifpinnacle.com/privacy-cookies, https://www.thewarrantygroup.eu/uk/website-privacy-cookie-policy, www.call-assist.co.uk/privacy-policy.
- HMRC, who may then pass information on to a relevant overseas tax authority;
- Driver & Vehicle Licensing Agency (DVLA) in order to validate driving licence details;
- law enforcement bodies in order to comply with any legal obligation or court order;
- third party lenders with whom we have a relationship, in case we do not wish to lend to you but another lender might (in particular Everyday Loans and Trust Two). We will tell you before we do this and give you the opportunity to choose whether or not to allow your information to be shared in this way. If you want any information about how Everyday Loans and Trust Two process your information, please visit their websites at www.everyday-loans.co.uk, www.trusttwo.co.uk/legal.
- where you have agreed to receive such marketing, we may make your details available to reputable suppliers of credit and insurance related services that we feel may be of interest to you;
- we reserve the right to sell accounts. In some circumstances, the firm to whom we sell accounts may require us to continue to process personal information. We will inform you if we do this; and
- for OneBill - third party companies you have set up as liabilities on your account that we make payments to;
- for motor finance, we pass the vehicle registration number and details of the vehicle to CAP HPI to record our interest in the vehicle. CAP HPI provide services to the motor industry on new car pricing and specifications, used car valuations, predicted maintenance costs and market analysis. They maintain a register of lenders with hire purchase agreements related to vehicles. For more information on how CAP HPI process your information, please visit their website at cap-hpi.com/pages/privacy.
Transfer outside of the EEA
Recipients with whom we share your personal information, for example our service providers, may be located in the UK, other countries in the European Economic Area or elsewhere in the world. Different privacy laws may apply in these countries and you understand and unambiguously agree to the transfer of personal information to these countries and parties.
Whenever we or our service providers transfer your personal information outside of the European Economic Area, we or they impose the standard contractual obligations approved by the European Commission on the recipients of that information to protect your personal information to the standard required in the European Economic Area or require the recipient to subscribe to 'international frameworks'. More details on the standard contractual obligations and the international frameworks are available on the ICO's website, or you can contact our Data Protection Officer on the details below.
We record and monitor communications with us, including electronic communications, video conferencing technology and calls, to improve the quality of our service and for your protection and security.
Sharing with Credit Reference Agencies
Before we offer motor finance, we will undertake checks with credit reference agencies for the purposes of assessing whether to lend to you. These checks require us to process personal information about you and include credit scoring. We continue to undertake these checks after we have given you motor finance to evaluate our risk and for statistical analysis (see 'Statistical Analysis' section).
In order to process the application for a business of which you are shareholder, director, partner, beneficial owner, authorised signatory or other associated person, we will undertake checks on you for the purposes of detecting and preventing crime, fraud and money laundering, and to verify your identity. These checks require us to process your personal information with the credit reference agencies and fraud prevention agencies. We continue to conduct regular or extraordinary checks for the same purposes while you have a relationship with us, for example an annual check with credit reference agencies and fraud prevention agencies or for a change in company structure.
Automated decision making is used for some motor finance applications (see 'Automated Decision Making' section).
Credit reference agencies add to the record about you, and your partner or anyone else with whom you are financially linked, information about your application and repayment history, including any default or failure to keep to the terms of an agreement with us.
Credit reference agencies hold your personal information for up to six years.
Any information you disclose to us that is false or inaccurate will also be recorded by the credit reference agencies. These records will be shared with other organisations and may be used and searched by us and them to:
- consider applications for credit and credit related services, such as insurance, for you and any associated person; and
- trace customers, recover debts, prevent or detect money laundering and fraud, and to manage accounts.
We use Equifax, TransUnion and Experian as our credit reference agencies. More information about the credit reference agencies and how they process your personal information is available at: www.equifax.co.uk/crain, www.transunion.co.uk/crain and www.experian.co.uk/legal/crain.
You can also find information about the credit reference agencies on the website of the Information Commissioner's Office at www.ico.org.uk/for-the-public/credit
For crime and fraud prevention and anti-money laundering
Before we offer a product or service, we will undertake checks for the purposes of detecting and preventing crime, fraud and money laundering, and to verify your identity. These checks require us to process your personal information with the credit reference agencies or fraud prevention agencies. We may ask you to provide additional information. We continue to undertake these checks even after we have given you an account, for the same purposes.
The consequences of these checks may mean that:
- If we determine that you may pose a risk of non or late repayment, we may refuse to lend to you.
- If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to open an account for you or to lend to you, or we may require repayment of your mortgage or loan or we may stop providing existing services to you.
If you have an agreement with us (for example, if we wish to require the repayment of an existing loan) then the terms of that agreement will dictate how we do this.
A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services or financing or employment to you. If you have any questions about this, please contact the fraud prevention agencies on the details below.
We, and fraud prevention agencies, may also enable law enforcement agencies or relevant authorities to access and use your personal information to detect, investigate and prevent crime.
Fraud prevention agencies hold your personal information for up to two years, and if you are considered to pose a fraud or money laundering risk, your information is held for up to six years.
The fraud prevention databases we use are provided by CIFAS - The UK's Fraud Prevention Service, Synectics Solutions, Experian, TransUnion, Lexis Nexis and Thomson Reuters. Further information can be found at www.cifas.org.uk, www.synectics-solutions.com/, www.experian.co.uk/crain, www.transunion.co.uk/crain, www.lexisnexis.co.uk/en-uk/, www.tr.com/privacy-information.
Automated Decision Making
As part of the processing of your personal information, some decisions for motor finance are made by automated means.
Our processes to verify your identity and undertake checks to detect and prevent money laundering checks can result in an automated decision. This means we automatically decide that you pose a fraud or money laundering risk if:
- our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers;
- is inconsistent with your previous submissions; or
- you appear to have deliberately hidden your true identity.
In some cases, we also use automated decision making to decide whether to offer you a motor finance loan and the rate of interest for the loan, whether we think that you can afford the loan and will abide by the terms of any loan agreement including whether you will repay the loan. This will involve us using logic to process different sources of information about you, such as from credit reference agencies, as well as our own algorithms to control our risk. Credit scores are produced from information such as credit commitments, whether you have made repayments on time, whether you have any history of insolvencies or court judgements, and how long you have lived at your current address. Our automatic decision may also be affected if we do not have enough statistically significant data about others who have similar circumstances to you to confidently assess our risk.
In some cases, if you are in financial difficulties, we use automated decision making to decide the most appropriate option to assist you.
If we make a decision solely on the basis of automated decision making, you have rights, for example, you can request human intervention and ask us to reconsider your application. If you want to know more please contact Customer Services.
If you owe us money, or if we suspect fraud, we process your personal information in connection with pursuing the recovery of that money or prevention of that fraud. We disclose information about non-payment, late payment or suspected or actual fraud to credit reference agencies, fraud prevention agencies, and law enforcement or government agencies in accordance with the law. We may share your personal information with independent debt recovery agencies or service providers, tracing agents or investigators, solicitors or other agents in order to recover monies you owe us. We use additional sources of personal information such as data obtained from providers of debt recovery agencies or fraud prevention agencies and we also process other personal information about you such as CCTV footage and information that you make public, for example on social media.
In the unfortunate circumstance that one of our customers passes away, we share the name, address, telephone number, and email address of the next of kin and any executors of the estate with our third party service provider in order to recover monies from the estate.
We use personal information of individuals who have applied for a product with us (whether accepted or declined) for statistical analysis to create scorecards in connection with the assessment of credit-worthiness, fraud and risk, to refine lending, risk and fraud strategies, and for analysis such as loss forecasting.
The personal information we use is shared with and obtained from credit reference agencies and fraud prevention agencies. Wherever possible, this information is processed on an anonymised basis. The credit reference agencies will not add a record to your credit file of processing conducted for this purpose.
We use personal information of individuals who have applied for a product or service with us (whether accepted or declined) to test scorecards and our internal systems and those of our third party service providers.
Testing can involve personal information being shared with and obtained from our third party service providers, credit reference agencies and fraud prevention agencies. Wherever possible, this information is processed on an anonymised basis. The credit reference agencies will not add a record to your credit file of processing conducted for this purpose.
From time to time, we may send you information regarding our products and/or services or those from carefully selected third parties, such as lenders and brokers, which we think may be of interest to you where we have your agreement. You opt to receive this information by letter, telephone, SMS and / or email.
If, at any time, you prefer not to receive further communications from us in any or all forms (except in connection with information, products or services that you specifically request), you will have the ability to unsubscribe from such communications by means of a link provided in every e-mail that is sent to you by us or by contacting us. To unsubscribe from such communications by SMS, reply 'STOP' to the SMS.
From time to time, we may send you a request to take part in a customer survey for feedback or research purposes. This is in order to improve our products, processes and/or service. You may receive this information by letter, telephone, SMS and/or email.
If, at any time, you prefer not to receive these communications from us in any or all forms, you will have the ability to opt out. To opt out you can contact us by telephone, in writing or by using the link provided in every e-mail that is sent to you. To unsubscribe from such communications by SMS, reply 'STOP' to the SMS.
Third Party Websites
This website contains links to other websites. We accept no responsibility or liability for the content of other websites which are not under our strict control, in particular, we are not responsible for the protection and privacy of any information which you provide whilst visiting other websites and such sites are not governed by this Privacy Statement. Please see section titled 'Access to Website' in our Website Terms and Conditions for further details.
Emails sent via the internet can be subject to interception, loss or possible alteration, therefore we cannot guarantee their security. Although we will do our best to protect your personal information, we cannot guarantee the security of your information sent by email and therefore will have no liability to you for any damages or other costs in relation to emails sent by you to us via the internet.
The Website is not intended for use by individuals under the age of 18 without the agreement and involvement of a parent or guardian. We do not knowingly collect personal information from individuals under the age of 18.
We will keep this Privacy Statement under review and make updates from time to time. We will notify you of any major changes which will affect the processing of your personal data, for example if we change the credit reference agencies we use. We may make minor changes (such as to correct typographical errors, or to add information about other products or services which do not affect your personal information at this time) without notifying you.
Your data protection rights
You have the right to request copies of certain of your personal information within our custody and control and details of how we use that information. Your request can be made verbally or in writing.
If you think any of the personal information we hold about you is inaccurate, you can also request it is corrected or erased.
You also have rights, in certain circumstances:
- to object to our processing of your personal information;
- to request human intervention if a decision has been made solely on the basis of automated decision making;
- to require us to stop processing your personal information; and
- to withdraw your agreement to processing based on 'consent'.
You have a right to port personal information you have provided to us to a different service provider.
In relation to all of these rights, please call us or write to us:
Data Protection Officer
Secure Trust Bank
One Arleston Way
Solihull, B90 4LH
Telephone queries can be made to: 0121 693 9100.
Please note that we may request proof of identity when we receive your request.
Our aim is to please but we know that sometimes things go wrong. If you have a problem, we want to know. Our staff will be happy to help you either on the telephone or in writing. Should you need to write to us, please address your complaint to Customer Resolutions, One Arleston Way, Solihull, B90 4LH or submit a complaint using our online form available at https://www.securetrustbank.com/complaints-and-resolutions.
Data Protection Officer
If you are unhappy about how your personal information has been used, please contact our Data Protection Officer using the details set out below. You also have a right to complain to the Information Commissioner's Office (https://ww.ico.org.uk), which regulates the processing of personal data.
Our Data Protection Officer can be contacted by telephone or in writing:
Data Protection Officer
Secure Trust Bank
One Arleston Way
Solihull, B90 4LH
Telephone queries can be made to: 0121 693 9100.