How we use your personal information

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 and medical conditions or biometric data (created for the purposes of facial recognition as part of the Digital ID Verification described below). 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, preventing or detecting unlawful acts or preventing fraud.

Withdrawing Consent

You have the right to withdraw your consent at any time. Please submit your request here if you wish to do so. This will not affect the lawfulness of any processing which has already happened based on that consent.

 

How we collect and obtain your personal information

We collect your personal information directly from you in several ways, including: 

• when you apply for a savings or credit product on our website (shawbrook.co.uk), through a postal application or direct with one of our employees; 
• when you provide it on-line or by any other method of communication, for example, on "contact us" forms, telephone or when you provide it through the course of our relationship, for example, if you inform us of a change in your circumstances or when you take part in our customer surveys;
• when you use our services;
• information you make public when you interact with our social media profiles or reference Shawbrook in your communication; and
• technical information, including the Internet Protocol (IP) address used to connect to the internet, may be collected from you when you visit our website.

We obtain your personal information indirectly from third parties including:

• information you have asked us (or a third party) to collect for you (for example information about your accounts or holdings with other companies including transaction information);
• through one of our partner organisations (for example, a credit broker, a supplier of retail, home improvement, motor or holiday ownership goods and services or a provider of investment or wealth management services) on their website, in-store, or if you visit their office or if they visit your home;
• comparison websites;
• following an introduction to us by another third party, such as an accountancy firm, law firm or management consultancy;
• if another person provides your information to us when they apply to obtain a product from us on your behalf; or that is to be held jointly with you; or on behalf of a business, charity, trust or other organisation of which you are a director, shareholder, owner, trustee or beneficiary (as applicable);
• from fraud prevention agencies, credit reference agencies, tracing and debt recovery agents, government bodies and agencies, the electoral roll, Companies House and other sources of publicly available information (e.g. sanctions list, media) when we carry out searches for the purposes of processing your application and/or during your relationship with us;
• if you occupy a property which we hold or propose to hold as security; or
• if you have a credit agreement with another lender and we buy it from that lender (for example, if we buy a portfolio of credit agreements and your credit agreement is included within that portfolio).

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.

Who your personal information may be shared with

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:

• Shawbrook Group parent entities for the purposes of enabling our parent entities to exercise oversight of our business.
• Shawbrook Group companies such as The Mortgage Lender Limited.
• Anyone acting on your behalf with authority to do so, such as a debt charity, power of attorney or your professional advisors.
• Credit reference agencies (CRAs), fraud prevention agencies and law enforcement agencies.
• Debt collection agencies to seek to recover any debt owed to us.
• Price comparison websites where you have been referred to us from that website
• Other financial service companies, such as other lenders.
• Legal and regulatory bodies, such as the Financial Conduct Authority (FCA), the Prudential Regulation Authority (PRA), HMRC, the Information Commissioner's Office (ICO), the UK Financial Services Compensation Scheme (FSCS), the Financial Ombudsman Service (FOS), our professional advisors and/or the courts.
• Organisations that provide us with business support services. For example, account service and administration companies, back-up and server hosting, IT software and maintenance platforms, document storage and management services, receivers, repossession agents, recoveries agents and property valuers.
• Third parties who have introduced you to us or are involved in the introduction process (e.g. an intermediary, broker, network or Mortgage Club).
• Market research organisations who we engage to assist us in developing and improving our products and services.
• Any person or entity that is to provide, or has provided, any security or guarantee (and their professional advisors) in respect of your agreement with us and their professional advisors.
• Any entity (and their professional advisors) that provides funding to us or members of the Shawbrook Group (for example, the Bank of England) and any entity that provides us with debt or equity finance. 
• Any purchaser or potential purchaser of any part of our business in the event that the Bank, or part of its assets were to be acquired by a third-party purchaser.
• Our PR and Communications partners when you enter our prize draws.
• Payment service providers whose services include money laundering and credit checks.

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.

Credit reference Agencies (CRAs)

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:

• Identity and contact data;
• Information from your credit application;
• Information about your financial situation and financial history;
• Public information (including the electoral register);
• Shared credit details; and
• Fraud prevention information.

We will use this information to:

• Assess your creditworthiness and whether you can afford to take the product;
• Verify the accuracy of the data you have provided to us;
• Prevent criminal activity, fraud and money laundering;
• Manage your account(s);
• Trace and recover debts; and
• Ensure any offers provided to you are appropriate to your circumstances.

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:

• TransUnion (formerly Callcredit)
• Equifax
• Experian

Fraud Prevention Agencies

The personal information we have collected from you will be shared with fraud prevention agencies to help us make credit related decisions. Fraud prevention agencies will also use your personal information 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.

International transfers of your personal information

We will only transfer your information outside the European Economic Area (EEA) when the law permits us to do so and to:

• Follow your instructions
• Share data with our suppliers who support our business

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.

Automated processing

We use systems to make automated decisions about you or your business when:

• You apply for our products and services, we undertake credit checks to assess creditworthiness and affordability and provide you with a tailored offer based on the results of our assessment;
• We carry out assessments to help decide if your personal or business accounts may be being used for fraud or other financial crime;
• We undertake anti-money laundering and sanctions checks; and
• We verify your identity.

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.

Digital ID Verification

When a new account is opened or a new individual is added to an account within our savings and personal loan division, if you fail to validate your identity via our electronic identity verification process, you will have the opportunity to verify your identity through our Digital ID Verification, which involves automated decision-making.

This Digital ID Verification involves solely automated decision-making, meaning there is no human involvement in making the decision. This is used to determine whether you pass or fail the Digital ID Verification for the purpose of determining whether you should be granted access to your account despite having initially failed to validate your identity via our electronic identity verification process.

We carry out this automated decision-making in order to comply with our regulatory requirements to detect and prevent crime. The Digital ID Verification is necessary in the circumstances described above to enable us to verify your identity, to protect you against identity theft and detect fraud.

How the Digital ID Verification Works

• If you fail to validate your identity via our electronic identity verification process, you will be sent a hyperlink to the email address provided when you applied for an account by one of our trusted third party suppliers asking whether you wish to verify your identity via the Digital ID Verification. The link will expire 48 hours after being sent, but you can request a new link following expiry.
• If you wish to proceed, you will be instructed to upload and submit: (i) a copy of your driving licence, passport or other acceptable form of ID; and (ii) a photo of yourself.
• Our trusted third party supplier will then use a specialised software program to: (i) verify the identification documentation submitted; (ii) compare the name and date of birth recorded in the document with the corresponding information we have on file for you; and (iii) carry out a process of facial recognition, which involves comparing the photo of yourself that you submit with the photo in your identification documentation (in simple terms, this is done by taking a number of data points on the photographs and comparing them to check they're the same).
• The Digital ID Verification has predefined parameters and will automatically determine whether you pass or fail the Digital ID Verification.

On completion of the Digital ID Verification, we may still need to review your application. We generally will let you know the outcome of your application within 5 working days of valid completion of the application and passing identity checks.

Reviewing an Automated Decision

You may have rights over automated decisions depending on the lawful basis upon which we process your information.

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

For more information or to exercise these rights please submit your request here.

How long your personal information will be stored for

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.

Keeping your information secure

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.

Keeping your information accurate

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.

How we monitor your communications

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.

 

Changes to our Privacy Notice

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 Group

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 Buildings and Protection Limited, Shawbrook Group PLC, The Mortgage Lender Limited and its related parent company entities and funds.

Last Updated: February 2023