Last updated: October 2015
Who we are and our Group
Your information will be held by Bank of Scotland plc which trades as Halifax, part of the Lloyds Banking Group.
More information on the Group can be found at www.lloydsbankinggroup.com
Where we obtain your information
Your personal information will be held securely in Lloyds Banking Group systems so that we and any other companies in our Group that you have dealings with, either now or in the future, can manage your relationship with us. This will include information you provide when you apply to join our Intermediary Panel, and any additional information provided by you or others in various ways, including:
- In applications, emails and letters, during telephone calls and conversations with Lloyds Banking Group colleagues, when registering for services, in surveys, when you participate in competitions and promotions and when using Lloyds Banking Group company websites.
- From your use of services involving Lloyds Banking Group companies and what they know from operating your membership of our Intermediary Panels (including the creation of profiles used to uniquely identify you when you use our online services) which are used to help us combat fraud and other illegal activity; and
- Information Lloyds Banking Group companies receive from each other, from our business partners, and from other organisations such as credit reference agencies and fraud prevention agencies, whether in the course of providing services to you or otherwise, and from information we gather from your use of and interaction with our internet services and the devices you use to access them.
We will not retain your personal information for longer than is necessary for the maintenance of Lloyds Banking Group Intermediary Panels, or for legal or regulatory requirements.
How we share your information
We may share the personal information we hold about you across the Lloyds Banking Group for the following administrative activities:
- providing you with services and notifying you about either important changes or
- developments to the features and operation of services;
- responding to your enquiries and complaints;
- administering offers, competitions, and promotions;
- facilitating the secure access to online platforms
and also for the following data sharing activities:
- updating, consolidating, and improving the accuracy of our records;
- undertaking transactional analysis;
- arrears and debt recovery activities;
- testing new systems and checking upgrades to existing systems;
- crime detection, prevention, and prosecution;
- evaluating the effectiveness of marketing, and for market research and training;
- statistical and trend analysis, with the aim of developing and improving services;
- assessing lending, fraud and insurance risks across the Lloyds Banking Group;
- managing your relationship with the Lloyds Banking Group companies.
By sharing this information it enables us, and other companies in the Lloyds Banking Group, to better understand your needs and provide you with efficient services.
Your data may also be used for other purposes for which you give your specific permission, or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.
When we may share your information
We will treat your personal information as private and confidential, but may share it with each other and disclose it outside the Lloyds Banking Group if:
- allowed by this agreement;
- you have given your consent;
- needed by our agents, advisers or others involved in running services for you or collecting what you owe Group companies (such as unearned fee payments);
- needed by subcontractors to help us manage your records;
- HM Revenue & Customs or other authorities require it;
- the law, regulatory bodies, or the public interest permits or requires it;
- required by us or others to investigate or prevent crime;
- needed by market research companies to assist us in providing better products and services for you;
- other parties connected with your panel registration require it.
- required as part of our duty to protect your panel registration.
We will always ensure your information remains safe and secure.
Using your information to help prevent terrorism and crime
To ensure we are complying with the international fight against terrorism and other criminal activities we may need to disclose information to government bodies.
Sharing your information to assist with asset buying or selling
Lloyds Banking Group companies may in the future wish to sell, transfer or merge part or all of their business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it. If so, they may disclose your personal information to a potential buyer, transferee, or merger partner or seller and their advisers so long as they agree to keep it confidential and to use it only to consider the possible transaction. If the transaction goes ahead, the buyers, transferee or merger partner may use or disclose your personal information in the same way as set out in this notice.
Sharing personal information between third parties
Sometimes, when you submit business through a third party such as a mortgage club or mortgage packager, this may mean that your personal data will be shared with the other party.
How we manage sensitive personal information
The Data Protection Act defines certain information as 'sensitive' (racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences). If we ask you for some 'sensitive' details we will only use this information to provide the service you require and we will ask you for your explicit consent.
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. We may provide other services from centres outside the EEA (such as the USA and India) that do not have a similar standard of data protection laws to the UK. If so, we will require your personal information to be protected to at least UK standards.
How we use Credit Reference Agencies
Credit Reference Agencies (CRAs) collect and maintain information about consumers 'and businesses' credit behaviour. This includes Electoral Register, fraud prevention, and credit information - including details of previous applications and the conduct of your accounts - and public information such as County Court Judgements, decrees, and bankruptcies.
The information that Lloyds Banking Group companies and other organisations provide to credit reference agencies about you, your financial associates and your business (if you have one) may be provided to other organisations and used by them and us to:
- help make decisions, for example when:
- checking details on applications for credit and 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;
- detect and prevent crime, fraud and money laundering.
- check your credit history;
- verify your identity if you, or someone financially linked with you, applies for services;
- trace your whereabouts; and
- undertake research, statistical analysis and systems testing.
If a Lloyds Banking Group company needs to make a credit decision when you apply for a credit-based product or service (e.g. mortgage, personal loan, credit card, or current account) or to review the amount of credit it provides under an existing agreement, such as an overdraft, your records will be searched, along with those of anyone who is financially associated with you such as your spouse or partner. The CRA will keep a record of this search and place a "footprint" on your credit file, whether or not the application proceeds.
We may give details of your account and how you conduct it to credit reference agencies, including if you borrow and do not repay in full and on time. If you fall behind with your payments and a full payment or satisfactory proposals are not received within 28 days of a formal demand being issued, then a default notice may be recorded with the CRAs. Similar information may also be given about your other lending/credit relationships with members of the group. Any records shared with CRAs will remain on file for 6 years after your account is closed, whether it has been settled by you or as a result of a default. Other organisations may see these searches and updates if you apply for credit in the future, and these may affect your ability to borrow from other lenders.
If you apply for or hold an account in joint names, or tell us that you have a spouse or financial associate, a financial association will be created between your records, including any previous and subsequent names used by you. This means that your financial affairs may be treated as affecting each other. These links will remain on your and their files until such time as you or your partner is successful in applying for a disassociation with the CRAs to break that link. You must be sure that you have their agreement to disclose information about them. Searches may be made on all joint applicants, and search footprints will be left on all applicants records.
You have a right to apply to the credit reference agencies for a copy of your file.
We carry out most of our credit searches using Experian, but details of how you have run your account(s) may be disclosed to all the credit reference agencies. The information they hold may not be the same and there is a small fee that you may need to pay to each agency that you apply to. Their addresses are:
- Experian Consumer Help Service, PO Box 9000, Nottingham NG80 7WP or call 0844 481 8000 or log on to www.experian.co.uk
- Equifax plc, Credit File Advice Centre, PO Box 1140, Bradford BD1 5US or log on to www.equifax.co.uk
- CallCredit, Consumer Services Team, PO Box 491, Leeds LS3 1WZ or call 0870 060 1414 or log on to www.callcredit.co.uk
Using Fraud Prevention Agencies
We have systems that protect our customers and ourselves against fraud and other crime. Customer information can be used to prevent crime and trace those responsible. We will share your personal information from your application with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these 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 panel registrations and other facilities.
- Managing panel registrations or facilities.
- Recovering unearned fee payments.
Please contact us on 0345 602 7174 if you want to receive details of the relevant fraud prevention agencies. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
How we check your identity
We may ask you to provide physical forms of identity verification when you register to join our panel. Alternatively, we may search credit reference agency files in assessing your application. The agency also gives us other details and information from the Electoral Register to verify your identity. The agency keeps a record of our search, whether or not your application proceeds. Our search is not seen or used by lenders to assess your ability to obtain credit.
Undertaking Anti-Money Laundering checks
To comply with money laundering regulations, there are times when we need to confirm (or reconfirm) your name and address. This information may be shared with other group companies.
Using your details for contact
Making sure we deliver excellent service is very important to us and to do this various methods of communication may be used when sending you information. Most of the time you will be contacted by e-mail or telephone but you may also be contacted by text message where it is believed to be appropriate. You can ask us to stop sending these messages at any time. When we contact you by e-mail, we will only do this if we have ensured that using email will not put your information at risk, or, if you have requested we email you, that we have explained the risks of sending an "insecure" email and that you are happy to accept that risk.
In addition you may wish to choose a channel of communication that suits you when you need to contact us. If you need to email a Lloyds Banking Group company, we recommend you check their website to see if a secure email facility exists so that your email can be sent securely. If you send us emails in other ways, such as from your personal account, then remember that the message may not be secure and there is a risk that it could be intercepted. If you choose to send an "insecure" email, please keep the amount of confidential information you include to a minimum.
Recording phone 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.
Using information on social networking sites
As part of our ongoing commitment to understanding our customers better, we may research comments and opinions made public on social networking sites such as Twitter and Facebook.
Obtaining a copy of your information
Under the Data Protection Act you have the right of access to your personal data. The Act allows us to charge a fee of £10 for this service. If anything is inaccurate or incorrect, please let us know and we will correct it. For further details on how to request a copy of your information, please write to the:
Data Subject Access Request Team
Drop Zone C41
Using your personal information to contact you about products and services
Unless you have asked us not to, we and other Lloyds Banking Group companies may contact you by mail, telephone, email or text message about services available from the Group. In addition we may also contact you about services from selected companies outside the Group, which we believe may be of interest to you.
We promise not to contact you about everything - only if we think it could be appropriate and relevant to you. You may opt out of receiving this information at any time by calling us or writing to us.
Passing your information to other companies for their own direct marketing
Unless you have given us your consent, we will not provide information about you to companies outside our group to use for their own marketing purposes.
In general, you can visit Lloyds Banking Group websites without identifying who you are or revealing any information about yourself. However, cookies are used to store small amounts of information on your computer, which allows certain information from your web browser to be collected. Cookies are widely used on the internet and do not identify the individual using the computer, just the computer being used. Cookies and other similar technology make it easier for you to log on to and use our websites during future visits.
Changes to our Privacy Notices
We keep our privacy notice under regular review and we will reflect any updates within this notice.