In this Privacy Statement the terms, 'we' or 'us' means Secure Trust Bank PLC, registered in England and Wales 541132, and regulated by the Prudential Regulation Authority and the Financial Conduct Authority.
Your privacy is important to us, and we are committed to keeping your information secure and managing it in accordance with our legal responsibilities under applicable data protection laws. We are registered with the UK Information Commissioner's Office (ICO) as a data controller under registration number Z5741952.
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.
By accessing, browsing or otherwise using the Website you confirm that you have read and agree to this Privacy Statement. If you do not agree with any part of this Privacy Statement, you should not use the Website. If you are applying for one of our products or services online, in person or by phone and do not agree with any part of this Privacy Statement, you should not continue with your application.
What Information We Collect
We may collect personal information (which means any information about an individual whose identity is apparent or can be reasonably ascertained from such information) from you in connection with a service or product provided to you by us, including: your name, address, telephone number, email address, date of birth, employment details (including income), details of expenditure, passport information, driving licence details, bank details, credit history, insurance details, information regarding your dependants, IP addresses, transaction and credit card information. Where you identify as a 'vulnerable customer' (i.e. if you, due to your personal circumstances or personal characteristics, are especially vulnerable to financial detriment), we will collect personal sensitive details regarding this (e.g. health information regarding a disability, illness or impairment) (See section of Sensitive Personal Data below for further details). 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.
How We Collect Your Information
We may collect information provided in connection with the following activities:
- if you apply for or purchase any product or service from us (including where you apply on behalf of a corporate entity);
- where you provide information to us on our Website, in writing or over the phone (including via call recording);
- if you register interest in a job vacancy, or a product and/or service, request information or assistance from us or make a complaint;
- where information is provided to us from third parties including credit reference agencies, tax authorities, fraud prevention agencies, motor dealers, brokers and introducers; and
- if you use any other features of the Website that may be offered from time to time, and may require such information in order to utilise the feature.
Use of Your Information
Your information will be used by us in connection with the following purposes:
|Service Provision and Internal Processing|
|• to provide the product or service that you applied for;|
|• to evaluate risk in connection with the provision of our services, in particular mortgage, credit and credit related services (including lending and insurance risks). For further information, see section below on Credit Checking and Automated Decision Making;|
|• to confirm, update and improve our customer records;|
|• to validate claims (i.e. to ensure that your account is not being used without your agreement) and to report on the performance of an account;|
|• to troubleshoot problems with the Website, or to customise your experience on the Website;|
|• to assess what forbearance options are appropriate if you are in financial difficulties;|
|• to recover debts / money which you owe to us;|
|• to provide you with any information on the products or services you have requested, by completing an expression of interest form or otherwise (including to give you advanced notice of new products);|
|Management of Relationship|
|• to manage, analyse, understand and develop your relationship with us;|
|• to inform you about improvements to the Website;|
|• to keep you informed of any of our other/new products and services and identify and market products and services that may be of interest to you, where you have chosen to be made aware of this, and to assist in any future applications to us;|
|• to respond to any queries or complaints that you raise;|
|• to inform you if an application you have started is incomplete;|
|Training, Service Review and Statistics|
|• for training purposes and to enhance or review the service we provide or have provided to you;|
|• to conduct statistical analysis and research (where possible using anonymised data);|
|• to prevent, investigate and prosecute crime, fraud and money laundering;|
|• for auditing purposes;|
|• if we are obliged to disclose information by reason of any law, regulation or court order;|
|• to consider you for potential job opportunities where you complete a candidate registration form;|
|• to transfer information to any entity which may acquire rights in us;|
|• for any other purpose to which you agree.|
How We Might Share Your Information
The third parties with whom we may need to share personal information to help us provide services and products to you and to run our Website are:
- 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;
- entities who may or do acquire any rights in us for the purpose of a business sale or reorganisation;
- our advisors, for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
- service providers who need to know the information in order to provide us or you with a product or service (including our third party service providers who process information on our behalf to help run some of our internal business operations including email distribution, electronic signature processing, storage of customer documentation, our HR careers portal, IT services, customer services and for data analytics (using anonymised data));
- independent debt recovery agencies or service providers, solicitors or other agents for the purpose of collecting monies due or outstanding on your account;
- our partners including brokers, introducers, retailers and motor dealers we work with;
- insurance providers, in the event that you apply for an insurance product, for the purposes of underwriting, processing, claim handling and fraud prevention;
- third party credit providers, in particular Everyday Loans and Trust Two, at your request where you have been unsuccessful in applying for personal lending services and/or product(s); in which case Everyday Loans and Trust Two will become the relevant data controller;
- credit and fraud agencies (including Call Credit, Equifax, Sira and Cifas) to help make decisions for:
- mortgage, credit and credit related services, and to manage your accounts;
- for motor, household, credit, life and other insurance proposals and validating claims (which may flag up whether you are linked financially to another individual where you are applying for a joint mortgage or joint savings account, in which case you should make sure that such other individual is aware that their information is being included); and
- fraud prevention, debtor tracing, debt recovery, and to check your identity to prevent money laundering;
- HMRC, who may then pass information on to a relevant overseas tax authority. If you are required to pay tax in another country, then we may be required to disclose details of the interest earned on your accounts. Please note, if this condition applies, or we reasonably think that it might, we may also: (i) ask you to supply documents or other information which we need to comply with our legal obligations; or (ii) close your account if you do not respond or do not co-operate with us;
- law enforcement bodies in order to comply with any legal obligation or court order.
Occasionally, we may make your details available to reputable suppliers of credit and insurance related services that we feel may be of interest to you where you have agreed to receive such marketing.
We reserve the right to sell performing and non performing accounts. We will inform you if we do this.
These parties 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. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws.
Retention of Your Personal Information
The personal information that you provide will be retained by us in accordance with applicable laws. However, we will take reasonable steps to destroy or de-identify personal information we hold if it is no longer needed for the purposes set out above.
Sensitive Personal Data
Sensitive personal data includes information about an individual's health and other categories of personal information which are closely protected (e.g. criminal convictions). 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 agree that, to the extent that you have provided us with sensitive personal data, you provided it voluntarily and agree that we can use any sensitive personal data that you provide us to deliver products or services to you and/or determine your fitness to avail yourself of our products or services. Where possible we shall seek to minimise the collection and use of such sensitive personal data.
Credit Checking and Automated Decision Making
We carry out identification and verification and anti-money laundering checks when you apply for any of our products and/or services. We carry out bankruptcy checks on powers of attorney. In addition, should you apply for a mortgage or credit product (and at any time whilst you are a customer), we may use a credit scoring system and may search your records, including fraud prevention databases at credit reference agencies. We will monitor and record information relating to your credit performance and such records may be shared with credit reference agencies in order to assess future applications for credit by you or other members of your household and for fraud prevention. Any searches will be recorded by the credit reference agencies and will be seen by other organisations making later searches. Any information you disclose that is false or inaccurate will also be recorded by the credit reference agency.
Credit scoring is an automated decision. If we reject your application solely on the basis of a credit scoring system, you can request human intervention and ask us to reconsider your application.
From time to time, we may send you information regarding products that we perceive may be of interest to you (including in relation to products and/or services of our partners where we have your agreement). You may receive this information by letter, telephone, SMS 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 (See section on Contact Us below).
Third Party Websites
This website may contain 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 our 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 data 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. If you would like to contact us, please see the section below or use our contact us page.
Except where we target particular products at a different age group, 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.
Keeping Your Information Secure
We invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.
We will keep this Privacy Statement under review and make updates from time to time. Any changes to this Privacy Statement will be posted on this page, so please review the Website periodically for changes. If you do not accept the amended Privacy Statement, you should stop using the Website; this may affect our ability to provide certain products and services to you. Please see the section regarding Your Rights for further information regarding continued processing.
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. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected or erased. You also have a right, in certain circumstances, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on 'consent', but this does not apply where we have other legal justifications to continue processing your data or an overriding legitimate interest (i.e. where processing is necessary for the performance of a contract).
In relation to all of these rights, please write to us at the address below. Please note that we may request proof of identity.
If you have a complaint about how we have handled your personal information you may contact us using the details below and we will investigate your complaint. You also have the right to lodge a complaint with a supervisory authority (i.e. the ICO) once you have tried to resolve the issue with us.
If you have any questions about this Privacy Statement, or you think we have incorrect information or you would like a copy of the information we hold about you, you may request details of personal information which we hold about you. Your request should be made in writing, (enclosing an administrative fee of £10 where you are requesting a copy of information) to:Data Protection Officer
Secure Trust Bank
One Arleston Way
Solihull, B90 4LH
Telephone queries can be made to: 0121 693 9100.