Shawbrook Bank Limited (the Bank, we, us and our) is committed to protecting your privacy. We have produced this notice to explain to you what personal information we have, how we get it and how and why we use that information.
Under data protection laws, we are a controller of personal information that we collect and hold about you. This is because we decide how and why your personal information is used.
If you have made an application on behalf of another individual, a joint application with another individual, or an application on behalf of a business, charity, trust or other organisation and have provided us with information in relation to its directors, shareholders, owners, trustees or beneficiaries (as applicable), then this privacy notice will also apply to them. It is important that they read this notice and we will assume that you have told them that their details will be shared with us and that you have shown them this notice.
If you want to receive a copy of the information we hold, exercise any of your information rights as explained in this notice or have any concerns or complaints about our use of your information, please use the contact us details on our website.
If we cannot resolve a complaint to your satisfaction you can contact the ICO at www.ico.org.uk or by telephoning 0303 123 113 if the complaint relates to the way we have handled your personal information.
You can contact our Data Protection Officer on 01277 751110, by email at DataPrivacy@shawbrook.co.uk or by writing to them at Shawbrook Bank Limited, Lutea House, Warley Hill Business Park, The Drive, Great Warley, Brentwood, Essex, CM13 3BE, if you have any questions about this privacy notice.
You can print a copy of this notice from our website or contact us for a copy.
Click on the links to find out more about how we use your information.
You have a number of rights which are explained below, if you wish to exercise any of these rights you can do so by using the contact us details on our website. We will explain whether the right applies to you as these rights do not apply in all circumstances. You will not have to pay a fee for exercising your rights. We try to respond within one month however if we think it will take longer than one month we will notify you and keep you updated. We will need to verify your identity before we can act on your request.
Right to access
You have the right to access the personal information held about you and to obtain certain prescribed information about how we process it. This is commonly known as submitting a 'data subject access request'.
Right to rectify your personal information
If you discover that the information we hold about you is inaccurate or incomplete, you have the right to have this information corrected.
Right to erasure
You may ask us to delete information we hold about you in certain circumstances, this is often referred to as the 'right to be forgotten'. This right is not absolute and only applies in particular circumstances. It may not always be possible for us to delete the information we hold about you, for example, if we have an ongoing relationship with you or we are required to retain information to comply with our legal obligations or to exercise or defend legal claims.
Right to restriction of processing
In some cases, you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, it may be restricted until the accuracy is verified, or where the processing is unlawful but you object to it being deleted and request that it is restricted instead.
Right to object to processing
You may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests or for the purposes of statistical analysis.
Right to object to direct marketing
You may also object to the processing of your personal information for the purposes of direct marketing and you can do this at any time using the contact us details on our website.
Right to data portability
You have the right to receive, move, copy or transfer your personal information to a controller which is also known as 'data portability'. This only applies to information you have given us and if we are processing your personal information based on consent or contract and the processing is automated.
The following list describes the different types of information we process about you, we explain why we process this information later in this notice:
The table below sets out the main ways we process your information, including for our legitimate interests. Processing necessary for the purposes of our legitimate interests, or those of a third party, is a type of lawful basis which applies to much of our processing. When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws.
Where we need to collect personal information by law, or under the terms of a contract we have with you, and you choose not to provide it, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
If you have any concerns about the processing below, you have the right to object to processing that is based on our legitimate interests. For more information on your rights, please see “Your Rights” section above.
|Purpose||Our lawful basis||Legitimate interests|
To consider and process your application.
|Performance of a contract with you.||
To decide whether we can offer you the product you have applied for and to evaluate any security and/or guarantee arrangements relating to a product.
|To perform credit and fraud searches and to verify your identity.||Necessary to comply with a legal obligation.||
To ensure we act as a responsible lender, including in regard to fraud prevention.
To administer your account in several ways which includes:
a. collecting loan repayments.
b. providing you with account statements, notices.
c. providing you with information such as changes to your interest rate.
d. managing any arrears on your account.
e. enforcing any security that we have in place.dealing with any queries or complaints that you may have.
Performance of a contract with you.
Necessary to comply with a legal obligation.
To recover debts due to us.
To keep our records updated.
To manage our business operations and our internal governance functions which includes:
a. monitoring communications and activities in relation to your account.
b. accounting and audit purposes.
c. complying with our corporate governance requirements.
d. providing you with relevant products and services.
e. business support services.
Necessary to comply with a legal obligation.Performance of a contract with you.
To measure our operations and performance against our business and compliance aims.
To run our business in an efficient and proper way.
To acquire your credit agreement from another lender which includes:
a. buying a portfolio of credit agreements where your credit agreement is included within the portfolio.
b. undertaking due diligence regarding the acquisition.
|Necessary to comply with a legal obligation.||To decide whether we wish to proceed with the acquisition or not.|
To respond to your request made to exercise your legal and regulatory rights (including those referred to in the ‘Your rights under applicable data protection law’ above.
|Necessary to comply with a legal obligation.|
Performing statistical analysis and conducting market research.
Assisting third parties (such as intermediaries or brokers) with their management operations and managing our use of third parties, which includes:
a. managing records about you.
b. ensuring the type of business that third parties refer to us is appropriate.
c. resolving any complaint made by you about a third party and/or any dispute between you and us regarding a third party.
|Necessary to comply with a legal obligation.||To ensure that the third party is fulfilling the terms of their contract with us and that we act as a responsible lender.|
To verify your identity as donor or lender of deposit monies or as occupier of any security property to ensure that there is no conflict in respect of parties' rights over the relevant security property.
|To ensure we can enforce our rights in respect of the security property through security provided.|
Testing and improving our products, services and systems.
|To ensure the security, efficiency and reliability of our products, services and systems.|
Criminal Conviction and Special Category Data
We will only process personal data relating to criminal convictions or offences and alleged offences where the law permits us to do so e.g. to perform checks to prevent and detect crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption and international sanctions or where we have your consent to do so.
Data protection law defines certain types of information as ‘special category data’. This includes details about your health or medical conditions. We will only process special category data where we have obtained your explicit consent to do so or another lawful basis exists, for example, where it is necessary for reasons of substantial public interest, namely to safeguard the economic well-being of individuals.
You have the right to withdraw your consent at any time. Please contact us if you wish to do so, This will not affect the lawfulness of any processing which has already happened based on that consent.
We collect your personal information directly from you in several ways, including:
We obtain your personal information indirectly from third parties including:
If you are applying to us indirectly through a third party, then they should have provided you with their own privacy notice and you should ask them for a copy if they did not.
So that we can provide you with products and services, meet our legal obligations and manage our business, it may be necessary to share your personal information with other third parties including:
Please note that our website may contain links to other third-party websites. These websites will not be governed by this notice and we therefore recommend that you read the privacy notices and cookie policies on the other websites you visit.
To process your application, we will perform credit and identity checks on you with one or more CRAs. Where you take banking services from us we will also make periodic searches at CRAs to manage your account with us. To do this, we will share your personal information with CRAs and they will give us information about you. This will include:
We will use this information to:
We will continue to share information about you with CRAs while you have a relationship with us. We will also inform the CRAs about your settled accounts. If you borrow and do not repay in full and on time, CRAs will record the outstanding debt. This information may be supplied to other organisations by CRAs. When CRAs receive a search from us they will place a search footprint on your credit file that may be seen by other lenders.
If you are making a joint application or tell us that you have a spouse or financial associate, we will link your records together, so you should make sure you discuss this with them, and share with them this information, before lodging the application. CRAs will also link your records together and these links will remain on your and their files until you or your partner successfully files for a disassociation with the CRAs to break that link.
The identities of the CRAs, their role also as fraud prevention agencies, the data they hold, the ways in which they use and share personal information, data retention periods and your data protection rights with the CRAs are explained in more detail in the CRA information notice (CRAIN) which is accessible from each of the three CRAs:
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity.
We may automatically decide that you pose a fraud or money laundering risk because of our fraud prevention searches or if our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers, or is inconsistent with your previous submissions, or you appear to have deliberately hidden your true identity.
If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services and financing you have requested, or to employ you, or we may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services, financing or employment to you.
Fraud prevention agencies can hold your personal data for different periods of time; if you are considered to pose a fraud or money laundering risk, note that your data can be held by them for up to six years. Further information in respect of how fraud prevention agencies may hold your personal information can be found here.
We will only transfer your information outside the European Economic Area (EEA) when the law permits us to do so and to:
If you enter into a contract with our subsidiary, Shawbrook International Limited, your personal information will be transferred outside the UK and the EEA to Jersey and Guernsey where it has offices, The European Commission has ruled that both Jersey and Guernsey, provide adequate protection for personal information under applicable laws.
Should we transfer your personal information to any other territories or countries outside the EEA we ensure appropriate safeguards are in place to maintain the same levels of protection as are needed under data protection laws in the UK. For more information you can contact us.
We use systems to make automated decisions about you or your business when:
Our automated decisions use profiling which means that we use your personal information to make decisions that can affect the products, services or features we may offer you now or in the future, or the price that we charge you for them. For example, if you do not meet an element of our lending criteria (such as being over 18 or being a resident in the UK) any application for credit will be automatically declined. If you do meet our lending criteria, the amount we lend, the term of your loan and the interest we charge on your loan will be determined by your credit status.
You may have rights over automated decisions depending on the lawful basis upon which we process your information.
For more information or to exercise these rights please contact us.
We only keep your personal information for as long as it is reasonably necessary to fulfil the purposes for which it is processed (as described above).
If your application is declined, we will store your personal information in accordance with our record retention procedures and to comply with our legal obligations.
In accordance with our retention policy, we will retain your personal information for a minimum of six years from the end of our business relationship with you. Our business relationship will be deemed to be at an end on the date upon which your account is closed (which will either be when all outstanding sums under the agreement have been repaid or when we stop pursuing arrears on the account) or when your application has been declined. Please note that if your personal information is shared with third parties (as detailed above) they may have different retention policies.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
For more information about how you can also protect yourself please read our Customer Security page.
We strive to ensure that your personal information is kept up to date and accurate. If any of the personal information you have given to us or third parties changes, such as your contact details, home ownership status, employment status or marital status, please promptly inform us in accordance with the terms and conditions of your agreement with us.
You will be required to provide us with any changes to your personal information under the agreement you enter into with us if your application for a credit or savings product is accepted. If you fail to do so this will put you in breach of your agreement.
Subject to applicable laws, we will monitor and record calls, emails, text messages, social media messages and other communications. We will do this for the purposes of complying with applicable laws and regulations and our own internal policies and procedures, to prevent or detect crime, to protect the security of our communications systems and procedures and for quality control and staff training purposes.
We keep this Notice under regular review and any updates will be posted on our website in the most recent version of the Privacy Notice. Where appropriate changes may be notified to you by post or email.
Shawbrook Bank Limited is registered in England and Wales. Registered company number: 00388466. Registered office: Lutea House, Warley Hill Business Park, The Drive, Great Warley, Brentwood, Essex, CM13 3BE.
The companies in the Shawbrook Group are Shawbrook Bank Limited, Shawbrook International Limited, Shawbrook Buildings and Protection Limited, Shawbrook Group PLC and its related parent company entities and funds.
Last Updated: January 2019