Last updated in April 2020
How we use your personal information
Your information will be held by the Lloyds Banking Group entity which provides the banking relationship(s) to the business. This is Housing Growth Partnership Manager Limited. This privacy notice is to let you know how companies within the Group look after your personal information. This includes what you tell us about yourself, what we learn by having the business as a customer, and your marketing choices. This notice also tells you about your privacy rights and how the law protects you.
This Privacy Notice covers personal information, and for the purpose of this Privacy Notice the following words have the following meanings:
“You/your” means Key Account Parties and Account Parties of the business. In this context “Key Account Parties” means individuals who are sole traders, partners, directors, company secretaries, member or beneficial owners, trustees or other controlling officials within the business. “Account Parties” means individuals (other than Key Account Parties) who have provided their personal information in connection with the products and services provided to the business by us.”
“The business” means the business you are associated with and which is our customer, whether it is a company, limited liability partnership, partnership, sole trader, or other entity such as a special purpose vehicle, club, charity or trust.”
|Personal information and the law||The control you have||How personal information is used|
|This section tells you who we are, what your personal information is, and how we get it. It explains how the law protects you by controlling what is allowed to happen to it.||This section covers how to complain or withdraw your consent. It also tells you how you can get a copy of your personal information, or ask for it to be changed or removed.||This tells you who we share personal information with. It explains what it’s used for in marketing, to provide credit and to combat fraud – and how this can affect you.|
|8. How to complain||13. Who we share your personal information with|
Personal information and the law
|Who we are
This section gives you the legal name of the company who holds your personal information – known as the ‘legal entity’ – and tells you how you can get in touch with us.
|Lloyds Banking Group is made up of a mix of companies, set up on different legal entities. We’ll let you know which you have a relationship with, when you take out a product or service with us.
You can find out more about us at www.lloydsbankinggroup.com.Contacting us about data privacy
If you have any questions, or want more details about how we use your personal 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 are not satisfied with our response, you can contact our Group Data Protection Officer via email@example.com and tell us you want to speak to our Data Protection Officer.
|How the law protects you
This section sets out the legal reasons we rely on, for each of the ways we may use your personal information.
|Data Protection law says that we are allowed to use personal information only if we have a proper reason to do so. This includes sharing it outside Lloyds Banking Group. The law says we must have one or more of these reasons:
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:
Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.
|Groups of personal information
This explains what all the different types of personal information mean, that are covered by data protection law.
|We use many different kinds of personal information. They are grouped together like this. The groups are all listed here so that you can see what we may know about you, even if we simply get it from seeing which shops you buy things in. We don’t use all this data in the same way. Some of it is useful for marketing, or for providing services to you. But some of it is private and sensitive and we treat it that way.
|Where we collect personal information from
This section lists all the places where we get data that counts as part of your personal information.
|We may collect personal information about you or the business from other Lloyds Banking Group companies and any of these sources:
Data you give to us
This covers data given by you as well as data provided by people linked with you or the business’s product or service, or people working on behalf of you or the business. This could mean a joint account holder, trustee, or fellow company director.
Data we collect when our services are used
Data from outside organisations
|How long we keep your personal information
This section explains how long we may keep your personal information for and why
|We will keep your personal information for as long as the business is a customer of Lloyds Banking Group.
We may keep your data for up to 10 years after the business stops being a customer. The reasons we may do this are:
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 personal information
You can choose not to give us personal information. In this section we explain the effects this may have.
|We may need to collect information by law, or to enter into or fulfil a contract we have with the business.
We may need to collect personal information by law, or to enter into or fulfil a contract we have with the business.
If you choose not to give us this personal 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 the business has with us.
|Cookies and similar tracking technologies
This section explains how we use data on our websites, apps and emails.
Cookies are small computer files that get sent down to your computer, tablet or mobile device by websites when you visit them. They stay on your device and get sent back to the website they came from, when you go there again. Cookies store information about your visits to that website, such as your choices and other details. Some of this data does not contain personal details about you or the business, but it is still protected by this Privacy Notice.
We may track emails to help us improve the communications we send. We may use small images called pixels within our emails to tell us things like whether you opened the email, how many times and the device you used. We may also set a cookie to find out if you clicked on any links in the email.
The control you have
|How to complain
This section gives details of how to contact us to make a complaint about data privacy. It also shows you where to get in touch with the government regulator.
|Please let us know if you are unhappy with how we have used your personal information. You can contact us using the details set out at the top of this notice.
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
|How to withdraw your consent
This section explains what to do if you change your mind about a consent you have given.
|You can get a copy of all the personal information we hold about you by filling in this form or writing to us at this address:
Commercial Banking DSAR Team
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
What if you want us to stop using your personal information? This section explains about your right to object and other data privacy rights you have – as well as how to contact us about them.
|You can object to us keeping or using your personal information. This is known as the ‘right to object’.
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:
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.
How personal information is used
|Who we share your personal information with
We may share your personal information with outside organisations such as credit card providers, insurers or tax authorities. This is so that we can provide products and services, run our business, and obey rules that apply to us. Here we list all the types of organisation that we may share your personal information with.Lloyds Banking Group
We may share your information with other companies in Lloyds Banking Group for any of the purposes outlined within this Privacy Notice. In particular, personal information may be shared within the Group where it helps us to confirm your identity, to contact you, to assess risks, to prevent and detect fraud or financial crime, and to provide our products and services efficiently.Authorities
This means official bodies that include:
Banking and financial services
Other services and schemes
Company mergers, takeovers, and transfers of products or services
|Sharing data that does not say who you are
We may share or sell some data to other companies outside Lloyds Banking Group, but only when it is grouped so that no-one’s identity can be known or found out.
We combine data in this way so we can look for general patterns and trends. For instance, we might look at customers in one age group shopping for clothes. We could look at one area of the UK, or the average amount spent in one month. But we would not include any data about who these customers are. When we combine data this way, we use all of the information – including historical data – that we hold about you, the business, and our other customers.
We do this to learn about the types of customers we have, how they use our products, and how our products perform for them. The law says this is not considered to be personal information after it has been grouped in this way.
How we work out what marketing you receive
We use marketing to let you and the business know about products, services and offers that may be of interest. This section describes how we decide what marketing to show or send. It also explains how we work out what may be interesting to you or the business.
|We may use your personal information to make decisions about what products, services and offers we think you or the business may be interested in. This is what we mean when we talk about ‘marketing’.
We can only use your personal information to send marketing messages if we have either consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information, and it must not conflict unfairly with your interests.
The personal information we have is made up of what you tell us, and data we collect when you or the business use our services, information we learn from the business, or from outside organisations we work with. We study this to form a view on what we think you or 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 information this way.
If allowed, we may show or send marketing material online (on our own and other websites including social media), in our own and other apps, or by email, mobile phone, post or through smart devices and other digital channels.
What you get will depend on marketing choices that we hold. You can change these at any time and tell us to stop sending you marketing.
You can also tell us not to collect data while you are using our websites or mobile apps. 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 personal information we have about you to outside organisations.
We may ask you or the business to confirm or update these choices, if the business takes out any new products or services with us in future. We will also ask for marketing choices to be confirmed or updated 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.
How we use your information to make automated decisions
Here we tell you how we use automated systems to make decisions about you and the business. We also explain the rights you have to challenge decisions using personal information made this way.
|We sometimes use systems to make automated decisions about you or the business. This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. Automated decisions can affect the products, services or features we may offer the business now or in the future, or the price that we charge for them. They are based on personal information that we have or that we are allowed to collect from others.
Here are the types of automated decision we make:
Tailoring products, services, offers and marketing
Detecting fraud and financial crime
Credit scoring uses data from three sources:
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.
This credit score can determine whether we will give credit, or allow another product or service to be taken.
If you want to know more about these rights, please contact us.
Credit Reference Agencies (CRAs)
This section explains how we work with outside companies to decide whether to lend money through products like credit cards or loans. It explains what we do and why we do it.
|We carry out credit and/or identity checks when the business applies for a product or service. We may use Credit Reference Agencies to help us with this.
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 information with CRAs and they will give us information about you. The information we exchange can include:
We’ll use this data to:
We will go on sharing your personal 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:
Fraud prevention agencies
This section deals with information we share outside our Group to help fight financial crime. This includes crimes such as fraud money laundering, sanctions screening, bribery, and terrorist financing.
|We may need to confirm your identity before we provide products or services to you or the business. This may include carrying out fraud and financial crime checks at the point of sale.
Once the business has become a customer of ours, we will share your personal information as needed to help combat fraud and other financial crime. The organisations we share data with are:
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 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 information. Even then, it must not unfairly go against your interests.
We will use the information to:
We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to prevent, detect, investigate and prosecute crime.
These other organisations can keep personal information for different lengths of time, up to six years.
The information we use
Automated decisions for fraud and financial crime prevention
We and other organisations acting to prevent fraud and financial crime may process your personal 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 the 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
This may result in other organisations refusing to provide you with products or services, or to employ you.
Data transfers out of the UK and EEA
Here is the web page for the information notice of the main Fraud Prevention Agency we use CIFAS
Sending data outside the UK and EEA
This section tells you about the safeguards that keep your personal information safe and private, if it is sent outside the UK and EEA.
|We will only send your data outside of the UK and European Economic Area (EEA) to: