The purpose of this policy is to explain to you what personal information we collect and how we and our associated companies may use it. The way in which information about you is held and used is also described in section D of our General Terms.
How we obtain and store your information We obtain your information through applications, emails, letters, telephone calls and conversations when registering for our services and during the course of our client relationship. In accordance with UK data protection legislation we follow strict security procedures in the storage and disclosure of information that you have given us, to prevent unauthorised access.
How we check your identity To comply with money laundering regulations we need to confirm the name and address of our customers. We may ask you to provide physical forms of identity verification when you open your account. Alternatively, we may use a credit reference agency to verify your identity. Our search is not seen or used by lenders to assess your ability to obtain credit.
Using your personal information The personal information we hold is only used for establishing and managing your account, to help us identify you when you contact us and supplying you with information regarding opportunities that we believe may be of interest to you. As a result we may send you marketing material from time to time by email, telephone, fax or other electronic messaging service unless you indicate to us that you would prefer not to receive it. If you do not wish to receive this information, please contact us.
Joint Applicants You should only give us personal information about someone else (such as a joint applicant) with their permission. Where information is provided by you about someone else, or someone discloses information about you, it may be added to any personal information that is already held by us and it will be used in the ways described in this privacy notice. Sometimes, when you open a joint account or product, this may mean that your personal data will be shared with the other applicant. For example, transactions made by you will be seen by your joint account holder and vice versa.
When we may share your information We, and our associated companies, may disclose your personal information to successors in title to our business and suppliers we engage to process data on our behalf. However, we do not sell, rent or exchange your personal information with any third party for commercial reasons beyond the essential requirement for debit or credit card validation when depositing or withdrawing funds, credit agencies and fraud prevention agencies.
Using your information to help prevent terrorism and crime Where we are required by law, your personal information may also be disclosed to an applicable governmental, regulatory or enforcement authority. These authorities may then use your personal information to investigate and act on any breach of law or regulatory rules in accordance with their procedures.
Using companies to process your information outside the EEA All countries in the European Economic Area (EEA), which includes the UK, have similar standards of legal protection for your personal information. In order to process debit or credit card transactions, the bank or card processing agency may require you to verify your personal details for authorisation outside the EEA (European Economic Area). If these are based outside the EEA, your personal information may not be protected to standards similar to those in the UK.
Training of staff We provide regular training to our staff on their privacy obligations. We regard data protection breaches very seriously and will enforce appropriate action whether the breach is deliberate or through negligence.
Recording telephone calls We may monitor or record phone calls with you in case we need to check we have carried out your instructions correctly, to resolve queries or issues, for regulatory purposes, to help improve our quality of service, and to help detect or prevent fraud or other crimes. Conversations may also be monitored for staff training purposes.
Obtaining a copy of your information Under the Data Protection Act you have the right at any time to request a copy of the personal data that we hold on you. The Act allows us to charge a fee of £10 for this service. We will respond within 40 days of receipt of your written request and the applicable fee. In order to maintain the accuracy of our database, you can update your personal details by contacting the Client Management Team.
Using cookies We use a technology known as “cookies” as part of a normal business procedure to track patterns of behaviour of visitors to our site. A cookie is an element of data that our website sends to your browser which is then stored on your system. We may store any information collected about you in this way which can be used to identify you when you visit our site in future, unless you change your browser settings to switch off cookies. If you want to know how to do this please look at the help menu on your browser. Information on deleting or controlling cookies is available at www.AboutCookies.org. However, you may not be able to use all the interactive features of our site if cookies are disabled. Find out more about Cookies.
If you have any questions about privacy, please contact our Compliance department at Park House, 16 Finsbury Circus, London, EC2M 7EB.