Privacy Information

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes salary and details of income, savings, expenditure, tax position and details about your existing borrowings.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We will sometimes also collect special categories of personal data such as about your health or if you are a vulnerable adult.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when for instance you apply to open an account or when you contact us.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • Credit reference agencies
  • Disclosure and Barring Service
  • Your employer
  • Your landlord
  • Other lenders
  • HMRC
  • DWP
  • Debt recovery and/or tracing agents
  • Police and law enforcement agencies
  • Publicly available directories and information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Keeping in contact with you

We may use your home address, phone numbers and email address to provide you with important information about your accounts. We will never ask you to reveal your password or personal information by email.

In addition, we may use your contact details to contact you with marketing information about our other products and services which may be of interest to you.  Currently, we only do this by post. You will have the opportunity to opt out of receiving such marketing information when you first provide your details to us, and you can change your mind at any time by contacting our DPO.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Guarantors (if applicable)
• Joint account holders, trustees and beneficiaries and any person with power of attorney over your affairs
• Other payment services providers
• Other account holders or individuals
• Broker or intermediary who introduced you to us
• Our legal or other professional advisers, auditors and actuaries
• Financial institutions
• Law enforcement agencies
• Courts
• Organisations that provide services to us
• Credit reference agencies
• Buyers and their professional representatives as part of any restructuring or sale of business or assets
• Market research organisations

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Your personal information is stored within the UK and we do not routinely transfer your personal information outside the UK.  Where a problem arises on your account, we may need to allow access to your information from our subcontractor based outside the UK (currently in India). Where we contract with such providers then if your personal information is processed within the European Economic Area (EEA) it is protected by European data protection regulation. Some countries outside the EEA also have adequate protection for personal information under laws that apply to us. We have put in place measures to ensure that your personal information is protected if it is required to be accessed from outside the EEA.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

How long will you use my personal data for?

We will generally hold your information for the whole time that you have an account with us, and for a period of six years after your account is closed. In some circumstances we may keep your information for longer than this, for instance where we are required by law to do so or where we need to retain your information to defend or exercise our legal rights.  We may also retain transactional history for statistical research and reporting reasons.

Where the personal information is not related to an account (for instance if you have enquired about our services but have not opened an account) we will generally only keep your information for the time it takes to deal with your enquiry and for a period of 12 months.

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data.

• The right to be informed
  We are required to be transparent with you about the processing that we do with your personal information. This is why we have a privacy notice.
• The right to request correction of your personal data
  We are required to correct your personal information if it is accurate or if personal information is incomplete.  If we have disclosed the personal information in question to other organisations, we must inform them of the correction where possible.
• The right to request erasure of your personal data
  This right is not absolute.  It only applies in certain circumstances and, where it does not, we will tell you at the time of your request.  We will not be able to comply if we are required to keep your personal information in order to comply with a legal obligation or to exercise or defend claims.
• The right to request access to the personal information held about you.
  This is known as a subject access request. It enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• The right to object to processing of your personal data.
  You have the right to object to our processing of your personal data where it is based on our legitimate interest, where it is processed for direct marketing or where it is processed for the purpose of statistics.
• The right to request restriction of processing your personal data
  This right enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• The right to request a transfer of your personal data
  This right only applies where personal information is being processed based on your consent or for performance of a contract and is carried out by automated means.
• The right to withdraw consent at any time
  This right is applicable when we are relying on consent to process your personal data.  However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.  If you withdraw your consent, we may not be able to provide certain products or services to you.  We will advise you if this is the case at the time you withdraw your consent.  

If you wish to exercise any of these rights against the credit reference agencies or a broker or other intermediary, you will need to contact them separately.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at dpo@swansea-bs.co.uk

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.