1. Who we are
2. How the law protects you
3. Groups of Personal Information
4. Where we collect personal information from
5. How long we keep your personal information
6. If you choose not to give personal information
7. Cookies

1. How to complain
2. How to withdraw your consent
3. Letting us know if your personal information is incorrect
4. How to get a copy of your personal information
5. Your rights

1. Who we share your information with
2. How we work out what marketing the business receives
3. How we use information to make automated decisions
4. Credit Reference Agencies (CRAs)
5. Fraud and Financial Crime prevention agencies
6. Sending data outside of the EEA

Contacting us about data privacy
If you have any questions, or want more details about any of the topics in this Privacy notice or how we use your personal and business information, you can ask your usual HGP contact, or email the data privacy team at CBDataPrivacy@Lloydsbanking.com.

These are our main contact details. Some sections of this notice have special contact details that you can use instead.

If you feel we have not answered your question Lloyds Banking Group has a Group Data Privacy Officer, who you can contact via info@housinggrowth.com and tell us you want to speak to our Data Privacy Officer.

• To fulfil a contract we have with you, or
• When it is our legal duty, or
• When it is in our legitimate interest, or
• When you consent to it.

When we have a business or commercial reason of our own to use your information, this is called a ‘legitimate interest’. We will tell you what that is, if we are going to rely on it as the reason for using your data. Even then, it must not unfairly go against your interests.

The law and other regulations treat some types of sensitive personal information as special. This includes information about racial or ethnic origin, sexual orientation, religious beliefs, trade union membership, health data, and criminal records. We will not collect or use these types of data without your consent unless the law allows us to do so. If we do, it will only be when it is necessary:

• For reasons of substantial public interest, or
• To establish, exercise or defend legal claims.

Here is a list of all the ways that we may use your information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.

Personal and business information  given to us

• When the business applies for our products and services
• When you talk to us, for example, on the phone or in meetings with your Relationship Manager, including recorded calls and notes we make
• When you use our websites, mobile device apps, web chat or SignVideo services
• In emails and letters
• In insurance claims or other documents
• In financial reviews and interviews
• In customer surveys
• If you take part in our competitions or promotions.

Personal and business information we collect when our services are used
This covers two things: details about how and where you access our services, and account activity that is shown on statements.

• Payment and transaction data
  This includes the amount, frequency, type, location, origin and recipients.
  If the business borrows money, it also includes details of repayments and whether they are made on time and in full.
• Profile and usage data
  This includes the security details you create and use to connect to our services. It also includes your settings and marketing choices. We also gather data from the devices you use (such as computers and mobile phones) to connect to our internet, mobile and telephone banking services.
  We also use cookies and other internet tracking software to collect data while you are using our website or mobile apps. You can find out more about this in our Cookies policy

Personal and business information from outside organisations:

• Companies that introduce the business to us (such as a store or car dealership offering finance deals through us)
• Financial advisers
• Credit card providers like Visa and Mastercard
• Credit reference agencies such as Callcredit, Equifax and Experian
• Insurers
• Retailers
• Comparison websites
• Social networks (for instance, when you click on one of our Facebook or Google ads)
• Fraud prevention agencies
• Other financial companies (to help prevent, detect and prosecute unlawful acts and fraudulent behaviour)
• Employers
• Payroll service providers
• Land agents (such as firms who do property valuations for mortgages)
• Public information sources such as the Electoral Register or Companies House
• Loyalty schemes like Avios or Everyday Offers
• Agents, suppliers, sub-contractors and advisers
  These can be types of firm we use to help us run accounts and services. They can also be specialist companies who advise us on ways to develop and improve our business.
• Market researchers (who combine data from many sources to produce market trend reports and advice)
• Medical professionals*
• Government and law enforcement agencies

* For some insurance products, we may ask your GP or other medical practitioner to send us a report. We will only do this if we get your consent first.

After the business stops being a customer, we may keep your personal information for up to ten years. The reasons we may do this are:

• To respond to a question or complaint, or to show whether we gave you fair treatment
• To study customer data as part of our own internal research
• To obey rules that apply to us about keeping records

We may also keep your data for longer than 10 years if we cannot delete it for legal, regulatory or technical reasons. As an example, we have to hold pension transfer information indefinitely; and in cases of subsidence* we will keep insurance claims data for up to 15 years after you stop being a customer.

We will only use your personal information for those purposes and will make sure that your privacy is protected.

* Subsidence is when a building becomes unsafe or damaged by ground sinking around it.

If you choose not to give us this information, it may delay or prevent us from fulfilling our contract with the business, or doing what we must do by law. It may also mean that we cannot run the business’s accounts or policies. It could mean that we cancel a product or service the business has with us.

We sometimes ask for information that is useful, but not required by law or a contract. We will make this clear when we ask for it. You do not have to give us these extra details and it won’t affect the products or services your business has with us.

To find out more about how we use cookies, please see our Cookies Policy

You also have the right to complain to the regulator about the use of your personal information, and to lodge an appeal if you are not happy with the outcome of a complaint.

In the UK this is the Information Commissioner’s Office. Find out on their website how to report a concern.

In Jersey, please contact the Office of the Information Commissioner
In Guernsey, please contact the Office of the Data Protection Commissioner
In Isle of Man, please contact the Information Commissioner

If you withdraw your consent, we may not be able to provide certain products or services to the business.

If you want to do this, please contact us using the details set out at the top of this notice.

Commercial Banking DSAR Team
Lloyds Banking Group
1st Floor East
Tower House
Charterhall Drive
Chester
CH88 3AN

When you want to share your data with outside companies

You also have the right to get certain personal information from us as a digital file, so you can keep and use it yourself, and give it to other organisations if you choose to. If you wish, we will provide it to you in an electronic format that can be easily re-used, or you can ask us to pass it on to other organisations for you.

If you want to do this, please contact us using the details set out at the top of this notice

You can also ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to erasure’ or the ‘right to be forgotten’.

There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights.

You can ask us to restrict the use of your personal information if:

• It is not accurate
• It has been used unlawfully but you don’t want us to delete it
• It is not relevant any more, but you want us to keep it for use in legal claims
• You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.

If we do restrict your information in this way, we will not use or share it in other ways while it is restricted.

If you want to object to how we use your data, or ask us to delete it or restrict how we use it, please contact us using the details set out at the top of this notice.

Authorities
This means official bodies that include:

• Central and local government
• HM Revenue & Customs, regulators and other tax authorities
• UK Financial Services Compensation Scheme and other deposit guarantee schemes
• Law enforcement and fraud prevention agencies.

Banking and insurance services
Outside companies we work with to provide services to the business and to run our business.

• Agents, suppliers, sub-contractors and advisers.
  These are types of firm that we use to help us run accounts, policies and services.
• Agents who help us to collect what is owed to us.
• Credit reference agencies (such as Callcredit, Equifax and Experian)
• Someone linked with the business’s product or service.
  This could mean a joint account holder, trustee, or fellow company director.
• Other financial services companies (to help prevent, detect and prosecute unlawful acts and fraudulent behaviour)
• Independent Financial Advisors, accountants and auditors.
  This could be someone who advises you on things like pensions or life assurance. We won’t share any personal information unless they have your consent to ask us for it.
• Price comparison websites and similar companies.
• Employers (for instance, to confirm your identity if we ask for a mortgage reference)
• Companies you ask us to share your data with.
  This is to do with something called Open Banking, which gives you more freedom and control to use your own banking data. It can make it easier for you or your business to shop around for products like credit cards, savings and current accounts.

Insurers
We share personal information with insurance industry companies to process claims and help reduce fraud. We do that in these ways:

• If the business applies for insurance through us, we may pass your personal or business details to the insurer.
• If the business applies for insurance with us as the insurer, we may share your personal or business details with reinsurers.
• If the business makes an insurance claim, information you give to us or the insurer may be put on a register of claims. This will be shared with other insurers, our agents, suppliers and sub-contractors. In some cases we may also share it with our business partners, if you also have a relationship with them.

Other services and schemes
These are organisations that we may need to share your information with, because of what you can do with the product or service you have with us.

• If you have a business debit, credit or charge card with us, we will share transaction details with companies which help us to provide this service (such as Visa and Mastercard).
  This is needed to keep account balances and statements up to date, for example.
• If the business uses direct debits, we will share your data and the business’s information with the Direct Debit scheme.
• If the business has a product which has a loyalty scheme like Avios or Everyday Offers, we will share your data and the business’s information with that scheme.
• If the business has a product with benefits such as travel insurance or discount offers, we will share your data and the business’s information with the benefit providers. We may also share it with other companies involved in how the service is used (such as a private car park operator).
• If you or the business has a secured loan or mortgage with us, we may share information with other lenders who also hold a charge on the property.
  (For example, this could be the other party in a shared ownership scheme)

General business
Outside companies we use to help grow and improve our business.

• Companies we have a joint venture or agreement to co-operate with
  This might be a store or car dealership offering finance deals through us
• Organisations that introduce you or the business to us
  This might be a store or car dealership that offers finance deals through us, or a price comparison website.
• Market researchers.
  We send data which these firms combine with data from other sources to produce market trend reports and advice.
• Advisers who help us to come up with new ways of doing business.
  This might be a legal firm, IT supplier or consultancy.

Company mergers and takeovers
We may also share your personal information if the make-up of Lloyds Banking Group changes in the future:

• We may choose to sell, transfer, or merge parts of our business, or our assets. Or we may try to bring other businesses into Lloyds Banking Group.
  This is sometimes called Mergers & Acquisitions or ‘company takeovers’.
• During any such process, we may share data with other parties involved. We’ll only do this if they agree to keep it confidential and secure.
• If the change to our Group happens, then other parties may use this data in the same way as set out in this notice.

We can only use your personal or business information to send marketing messages if we have consent or a ‘legitimate interest’. By ‘legitimate interests’ we mean that we have a business or commercial reason to use your or the business’s information, and it must not conflict unfairly with your interests.

The personal and business information we have is made up of what you tell us, and data we collect when you or your business use our services, or from outside organisations we work with. We study this to form a view on what we think the business may want or need, or what may be of interest. This is how we decide which products, services and offers may be relevant.

This is called profiling for marketing purposes. You can contact us at any time and ask us to stop using your personal or business information this way.

If allowed, we may show or send your business marketing material online (on our own and other websites including social media), in our app, or by email, mobile phone or post.

What you get will depend on marketing choices that you set. You can change these at any time and tell us to stop sending you marketing.

We can stop collecting data while our websites or mobile apps are being used. If this is done, marketing will be seen but it will not be tailored. See our Cookies policy for details about how we use this data to improve our websites and mobile apps.

With any option, we will still send statements and other important information such as changes to any existing products and services.

We do not sell the information we have to outside organisations.

We may ask your business to confirm or update these choices, if your business takes out any new products or services with us in future. We will also ask your business to do this if there are changes in the law, regulation, or the structure of our business.

If you change your mind you can contact us to update your choices at any time.

Here are the types of automated decision we make:

Pricing
We may decide what to charge for some products and services based on what we know. If the business applies for insurance, we will compare what you tell us with other records to work out how likely the business is to make a claim. This will help us decide whether to offer the product and what price to charge.

Tailoring products, services, offers and marketing
We may place the business in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products, services and offers for different customer segments, and to manage our relationships with them. It also helps us tailor the marketing that we send or that is shown on our own and other websites and mobile apps, including social media.

Detecting fraud and financial crime
We use your or the business’s information to help decide if the business’s accounts may be being used for fraud, financial crime or breaching sanctions. We may detect that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. If we think there is a risk of fraud or financial crime, we may stop activity on the accounts or refuse access to them.

Opening accounts
When accounts are opened with us, we check that the product or service is relevant for the business, based on what we know about the business. We also check that you or the business meets the conditions needed to open the account. This may include checking age, residency, nationality, place of incorporation or financial position.

Approving credit
We use a system to decide whether to lend money to the business, when it applies for credit such as a loan or credit card. This is called credit scoring. It uses past data to assess how the business is likely to act while paying back any borrowing. This includes data about similar accounts you or the business may have had before.

Credit scoring uses data from three sources:

• The application form
• Credit reference agencies
• Data we may already hold.

It gives an overall assessment based on this. Banks and other lenders use this to help us make responsible lending decisions that are fair and informed.

Credit scoring methods are tested regularly to make sure they are fair and unbiased.

Your rights
As a person you have rights over automated decisions.

• You can ask that we do not make our decision based on the automated score alone.
• You can object to an automated decision, and ask that a person reviews it.

If you want to know more about these rights, please contact us.

If the business uses our services, from time to time we may also search information that the CRAs have, to help us manage those accounts.

We will share your personal and business information with CRAs and they will give us information about the business and you. The information we exchange can include:

• Name, address and date of birth
• Business name and address and (where applicable) date and place of incorporation
• Credit application
• Details of any shared credit
• Financial situation and history
• Fraud prevention information
• Public information, from sources such as the Electoral Register and Companies House.

We’ll use this data to:

• Assess whether you or your business is able to afford to make repayments
• Make sure what you’ve told us is true and correct
• Help detect and prevent financial crime
• Manage the business’s accounts with us
• Trace and recover debts
• Tell you about relevant offers.

We will go on sharing your personal and business information with CRAs for as long as the business is a customer. This will also include details of funds going into the account, and the account balance. If the business borrows, it will also include details of repayments and whether these are made in full and on time. We will also tell the CRAs when accounts are settled with us. The CRAs may give this information to other organisations that want to check your or the business’s credit status.

When we ask CRAs about you or the business, they may note it on your credit file. This is called a credit search. Other lenders may see this and we may see credit searches from other lenders.

If you apply for a product with someone else, we will link your records with theirs. We will do the same if you tell us you have a spouse, partner or civil partner – or that you are in business with other partners or directors.

You should tell them about this before you apply for a product or service. It is important that they know your records will be linked together, and that credit searches may be made on them.

CRAs will also link your records together. These links will stay on your files unless one of you asks the CRAs to break the link. You will normally need to give proof that you no longer have a financial link with each other.

You can find out more about the CRAs on their websites, in the Credit Reference Agency Information Notice. This includes details about:

• Who they are
• Their role as fraud prevention agencies
• The data they hold and how they use it
• How they share personal information
• How long they can keep data
• Your data protection rights.

Here are links to the information notice for each of the three main Credit Reference Agencies:
Callcredit
Equifax
Experian

Once the business has become a customer of ours, we will share your information as needed to help combat fraud and other financial crime.  The organisations we share data with are:

• Registered Fraud and Financial Crime Prevention Agencies (FFCPAs)
• Other agencies and bodies acting for the same purpose
• Industry databases used for this purpose
• Insurers

Throughout our relationship with the business, we and these organisations exchange data between us to help prevent, deter, detect and investigate fraud and financial crime.

None of us can use your personal information unless we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.

When we have a business or commercial reason of our own to use your personal information, this is called a ‘legitimate interest’. We will tell you what that is, if we are going to rely on it as the reason for using your personal data. Even then, it must not unfairly go against your interests.

We will use the information to:

• Confirm identities
• Help prevent fraud, financial crime, bribery and breaches of sanctions
• Fulfil any contracts you or the business has with us.

We or an FFCPA may allow law enforcement agencies to access your information. This is to support their duty to prevent, detect, investigate and prosecute crime.

These other organisations can keep information for different lengths of time, up to six years.

The information we use
These are some of the kinds of personal information that we use:

• Name
• Date of birth
• Residential address
• History of where you have lived
• Contact details, such as email addresses and phone numbers for you and the business
• Financial data
• Whether you have been a victim of fraud
• Data about insurance claims made
• Data relating to you or the business’s products or services
• Employment details
• Vehicle details
• Data that identifies computers or other devices you or the business use to connect to the internet. This includes your Internet Protocol (IP) address.

Automated decisions for fraud and financial crime prevention
The information we have for you or your business is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.

We and other organisations acting to prevent fraud and financial crime may process your information in systems that look for fraud and financial crime by studying patterns in the data. We may find that an account or policy is being used in ways that criminals work. Or we may notice that an account is being used in a way that is unusual for you or your business. Either of these could indicate a risk that fraud or financial crime may be carried out against a customer, the bank or the insurer.

How this can affect you
If we or an FFCPA decide there is a risk of fraud or financial crime, we may stop activity on the accounts or block access to them. FFCPAs and cross-industry organisations may also keep a record of the risk that you or your business may pose.

This may result in other organisations refusing to provide you with products or services, or to employ you.

Data transfers out of the EEA
FFCPAs and other organisations we share data with for these purposes may send personal information to countries outside the European Economic Area (EEA). When they do, there will be a contract in place to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.

• Follow your or the business’s instructions
• Comply with a legal duty
• Work with our suppliers who help us to run your accounts and services.

If we do transfer your personal information outside the EEA to our suppliers, we will make sure that it is protected to the same extent as in the EEA. We’ll use one of these safeguards:

• Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
• Put in place a contract with the recipient that means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website.
• Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. You can find out more about data protection on the European Commission Justice website