Direct interactions
We will generally collect your personal information from you directly, including application forms, letter and or email correspondence, secure messaging, telephone, or via our website/mobile device applications. If you are introduced to us by a broker or other intermediary, we will obtain some personal information about you indirectly from them when they introduce you to us.
Open Banking
Information we use when connecting to ‘Open Banking’
Consent to connect to Open Banking. With your permission, we access specific details about accounts you hold with other banks to help us make lending decisions. If you do not give us consent to access an account, this may affect the service we are able to offer you.
Information we get from banks. When you give us consent to access details about accounts you hold with banks so we can make lending decisions, we collect:
- Full legal name of any account holders and status (open/closed)
- your account number, sort code,
- your account balance
- details of all transactions going in and out in the last 12 calendar months.
The information that you provide will also allow us to analyse bank transaction data to assist with credit risk evaluation.
Third party and publicly available sources
In addition, we may obtain your personal information from other sources such as Fraud Prevention Agencies, Credit Reference Agencies, your employer, landlord, other lenders, HMRC, DWP, publicly available directories and information (e.g. telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies.
Some of the personal information obtained from Credit Reference Agencies will have originated from publicly accessible sources. In particular, Credit Reference Agencies draw on court decisions, bankruptcy registers and the electoral register (also known as the electoral roll). We explain more about Credit Reference Agencies below. We have also mentioned above in the lists of personal information that we process some of the Credit Reference Agencies’ other sources of information (which are our own source of information too).
When a broker or other intermediary processes your personal information on our behalf, this privacy policy will apply and you should contact us to exercise your rights under data protection laws. When a broker or other intermediary processes your personal information as a data controller in its own right, its own privacy policy will apply and you should ask them for a copy if you do not have one by the time you are introduced to us.
We may also obtain Technical and Profiling Data (defined in section 3) (by way of example) from the following third parties:
- analytics providers [such as Google based outside the UK];
- advertising networks [such as Facebook, Google, Bing based outside the UK];
- search information providers [such as Google and Bing based outside the UK]
and other third party analytics and or search providers.
We may also obtain Identity Data in the form of facial verification and recognition technology to verify identity.
Using Face Identification, Verification and Recognition Technology
You can apply for some of our products and services using a face recognition session from your mobile device to verify your identity and contact details.
If you use our face recognition service both the images and the audio will be recorded and may be used for training and monitoring services. We’ll use any personal data captured about you for the performance of a contract or/with a view to entering into a contract with us as well as for our legitimate interests for good governance, accounting, managing and auditing our business operations, and to monitor emails, calls other communications in relation to dealings with us.
For your own privacy and protection please ensure that your location doesn’t include items and images that you don’t wish to be recorded.
Secure Instant Messaging
We in our sole capacity or in conjunction with a broker or other intermediary engaged by us, may process your personal information to set up and administer your account. The secure instant messaging platform will be used to:
- provide (from us to you or you to us) correspondence, data, documentation and personal information as part of joining and applying for a mortgage and prior to and entering into a contract with us;
- provide images of documentation and yourself to support our identification checks, fraud and money laundering controls; and
- to discuss any queries about your account.
Electronic Signatures
We utilise electronic signature applications to enable contracts and notices to be signed. In utilising such tools our employees, brokers acting on our behalf, third party suppliers and you may provide limited personal data for the purposes of:
- business execution and in particular for the conclusion and execution of agreements between us and you;
- for compliance with legal or regulatory requirements including litigation and defence of claims; and
- for the prevention, detection and investigation of fraud.
Automated technologies or interactions
As you interact with us, we will automatically collect some Technical and Profile Data about your equipment, interactions, voice analysis, browsing actions, usage data and patterns. We collect this personal data by using cookies [server logs] and other similar technologies.
We may also receive Technical Data about you if you visit other websites employing our cookies. Please see section 16 ’Cookies’ below for further details.