How your personal information is used by Lloyds Banking Group companies
Last updated August 2011
1. Introduction
'Your information will be held by Lloyds TSB Bank Plc which is part of the Lloyds Banking Group
1.1 The Lloyds Banking Group includes us and a number of other companies using brands including Lloyds TSB, Halifax and Bank of Scotland, and their associated companies. More information on the Group can be found at www.lloydsbankinggroup.com.
1.2 Please read this Privacy Policy to understand how we use and protect the information that you provide to us through the “Website”.
1.3 By accessing any part of this Website or providing any information to us you consent to the use and transfer of your information on the terms set out in this Privacy Policy.
1.4 We reserve the right to revise or supplement this Privacy Policy from time to time at our sole discretion and you agree to revisit this page regularly to ensure that you are familiar with the most current version. By continuing to access or use the Website you will be agreeing to any such changes.
1.5 If you are a customer of a Lloyds Banking Group company, details of the information we collect and how we use it will also be set out in the terms and conditions of the product or service which you hold. In the event of a conflict between this Privacy Policy and the terms and conditions of your specific product or service, the terms and conditions of your specific product or service will take precedence.
2. Use of information collected
2.1 Domain name information that we collect is not used to personally identify you and instead is aggregated to measure the number of visits, average time spent on the Website, pages viewed etc. We use this information to measure the use of our Website and to improve its contents.
2.2 Your personal information will be held securely in Lloyds Banking Group systems so that we and any other companies in our Group that you have dealings with, either now or in the future, can manage your relationship with us. This will include information you provide when you apply to us, and any additional information provided by you or others in various ways, including:
(a) in applications, emails and letters, during telephone calls and conversations in branch, when registering for services, in customer surveys, when you participate in competitions and promotions, through Lloyds Banking Group company websites and during financial reviews and interviews
(b) from analysis (for example, the amount frequency, location, origin, and recipient) of your payments and other transactions, and your use of services involving other Lloyds Banking Group companies and what they know from operating your account; and
(c) information Lloyds Banking Group companies receive from each other, from our business partners, and from other organisations such as credit reference agencies and fraud prevention agencies.
We will not retain your personal information for longer than is necessary for the maintenance of your account, or for legal or regulatory requirements.
2.3 We may share the personal information we hold about you across the Lloyds Banking Group for the following administrative activities:
(a) providing you with products and services and notifying you about either important changes or developments to the features and operation of those products and services;
(b) responding to your enquiries and complaints;
(c) administering offers, competitions and promotions;
(d) undertaking financial reviews;
And also for the following data sharing activities:
(e) updating, consolidating, and improving the accuracy of our records;
(f) undertaking transactional analysis;
(g) arrears and debt recovery activities;
(h) testing new systems and checking upgrades to existing systems;
(i) crime detection, prevention and prosecution;
(j) evaluating the effectiveness of marketing and for market research and training;
(k) customer modelling, statistic and trend analysis, with the aim of developing and improving products and services;
(l) assessing lending and insurance risks across the Lloyds Banking Group;
(m) managing your relationship with the Lloyds Banking Group companies
By sharing this information it enables us, and other companies in the Lloyds Banking Group, to better understand your needs and run your accounts in the efficient way that you expect. Your data may also be used for other purposes for which you give your specific permission, or, in very limited circumstances, when required by law or where permitted under the terms of the Data Protection Act 1998.
2.4 We may also contact you about products and services available from Lloyds Banking Group companies, and from selected companies outside the group, which we believe may interest you or benefit you financially. We may do this by post or by phone unless you have told us not to; and by email, text or other electronic means if you have told us that we can or as otherwise allowed by law.
We promise not to contact you about everything – only if we think it could be appropriate and relevant to you, such as preferential savings opportunities, account upgrades or special offers. This contact may continue after your relationship with us ends. You may opt out of receiving this information at any time if you change your mind by calling us, writing to us, contacting your local branch or online. For more information on your marketing preferences please visit 'Your marketing preferences'.
Unless you have given us your consent, we will not provide information about you to companies outside our group to use for their own marketing purposes.
2.5 Making sure we deliver excellent customer service is very important to us and to do this various methods of communication may be used to keep you updated about your account. Most of the time we communicate by telephone or post but we recognise that email is becoming a more popular process. If we decide to use email to contact you, we will only do this if we have ensured that using email will not put your information at risk, or, if you have requested we email you, that we have explained the risks of sending an "insecure" email and that you are happy to accept that risk.
In addition you may wish to choose a channel of communication that suits you when you need to contact us. If you need to email a Lloyds Banking Group company, we recommend you check their website to see if a secure email facility exists so that your email can be sent securely. If you send us emails in other ways, such as from your personal account, then remember that the message may not be secure and there is a risk that it could be intercepted. If you choose to send and "insecure" email, please keep the amount of confidential information you include to a minimum. With some of our products we offer a number of communication update services via SMS. If you have signed up to this service, we may send you text messages containing administrative information about your relationship with us. You can ask us to stop sending these messages at any time. Additionally, in extraordinary circumstances (such as natural disaster or civil unrest) we may also send you updates by text message or email when we consider it to be appropriate.
2.6 We will treat your personal information as private and confidential, but may share it with each other and disclose it outside the Lloyds Banking Group if:
(a) allowed by this agreement;
(b) you consent;
(c) needed by our agents, advisors or others involved in running accounts and services for you or collecting what you owe Group companies;
(d) needed by subcontractors to help us manage your records;
(e) HM Revenue & Customs or other authorities require it;
(f) the law, regulatory bodies, or the public interest permits or requires it;
(g) required by us or others to investigate or prevent crime;
(h) needed by market research companies to assist us in providing better products and services for you; or
(i) to any other parties connected with your account (including guarantors)
(j) required as part of our duty to protect your accounts, for example we are required to disclose your information to the UK Financial Services Compensation Scheme (FSCS).
We will always ensure your information remains safe and secure.
2.7 If you were 'introduced' to us by a third party and/or have a relationship with or are supporting one of our affinity partners (eg a charity credit card account) we will give them your contact details and sufficient information about you to help with their accounting and administration. Introducers or affinity partners may use these details to contact you about products and services unless you have asked them not to do so.
2.8 The government also requires us to screen applications that are made to us to ensure we are complying with the international fight against terrorism and other criminal activities. As a result we may need to disclose information to government bodies.
2.9 Lloyds Banking Group companies may in the future wish to sell, transfer or merge part or all of their business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it. If so, they may disclose your personal information to a potential buyer, transferee, or merger partner or seller and their advisers so long as they agree to keep it confidential and to use it only to consider the possible transaction. If the transaction goes ahead, they buyers, transferee or merger partner may use or disclose your personal information in the same way as set out in this notice.
2.10 Sometimes, when you open a joint account or product, this may mean that your personal data will be shared with the other applicant. For example, transactions made by you will be seen by your joint account holder and vice versa.
2.11 The Data Protection Act defines certain information as 'sensitive' (racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences). If you apply to us for insurance, a pension, health insurance or life insurance, we may ask you for some 'sensitive' details. We will only use this information to provide the service you require and we will ask for your explicit consent. As a customer, there may be times when you give us sensitive information. We may share it with other parts of the group and our subcontractors to keep records up to date.
2.12 All countries in the European Economic Area (EEA), which includes the UK, have similar standards of legal protection for your personal information. Lloyds Banking Group companies may run your accounts and provide other services from centres outside the EEA (such as the USA and India) that do not have the same standard of data protection laws as the UK. However, if we do, we will require your personal information to be protected to at least UK standards. We may process payments through other financial institutions such as banks and the worldwide payment system operated by the SWIFT organisation if, for example, you make a CHAPS payment or a foreign payment. Those external organisations may process and store your personal information abroad and may have to disclose it to foreign authorities to help them in their fight against crime and terrorism. If these are based outside the EEA, your personal information may not be protected to standards similar to those in the UK.
2.13 We have systems that protect our customers and ourselves against fraud and other crime. Customer information can be used to prevent crime and trace those responsible. We will share your personal information from your application with fraud prevention agencies. If false or inaccurate information is provided and fraud is identified, details of this fraud will be passed to these agencies. Law enforcement agencies may access and use this information. We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:
(a) checking details on applications for credit and credit related or other facilities
(b) Managing credit and credit related accounts or facilities
(c) Recovering debt
(d) Checking details on proposals and claims for all types of insurance
(e) Checking details of job applicants and employees
Please contact us on 0845 604 5606 if you want to receive details of the relevant fraud prevention agencies. We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.
2.14 We may ask you to provide physical forms of identity verification when you open your account. Alternatively, we may search credit reference agency files in assessing your application. The agency also gives us other details and information from the Electoral Register to verify your identity. The agency keeps a record of our search, whether or not your application proceeds. Our search is not seen or used by lenders to assess your ability to obtain credit.
2.15 We may monitor or record phone calls with you in case we need to check we have carried out your instructions correctly, to resolve queries or issues, for regulatory purposes, to help improve our quality of service, and to help detect or prevent fraud or other crimes. Conversations may also be monitored for staff training purposes.
2.16 As part of our ongoing commitment to understanding our customers better, we may research comments and opinions made public on social media networking sites such as Twitter and Facebook.
2.17 By using the Website you consent to us using your personal information for the purposes described above.
3. Use of cookies
3.1 In general you can visit Lloyds Banking Group websites without identifying who you are or revealing any information about yourself. However cookies are used to store small amounts of information on your computer to enable our server to collect certain information from your web browser. Cookies are widely used on the internet and in themselves do not identify the individual, just the computer used. Cookies and other similar technology make it easier for you to log on to and use the Website during future visits.
3.2 Cookies are used in this Website by us and by third parties to:
• monitor and manage Website traffic;
• evaluate the effectiveness of our advertising and promotions (for example, we use a third party ad server – Double Click to manage advertising and to serve adverts on the Website through the use of cookies and pixel tags);
• to identify you when you visit the Website, to personalise the content of the Website for you and to enable you to both carry out transactions and have access to information about your account;
• temporarily to store details input into calculators and other tools on the Website; and
• If required as a matter of law or regulation, in order to protect our or our other customers’ rights.
3.3 Cookies themselves only record which areas of the Website have been visited by the computer in question, and for how long. Allowing us or a third party to create a cookie does not give us access to your computer and we will not use cookies to track your online activity once you leave the Website. Cookies are read only by the server that placed them, and are unable to execute any code or virus.
3.4 With most internet browsers, you can erase cookies from your computer hard drive, block all cookies or receive a warning before a cookie is stored. If you want to know how to do this please look at the help menu on your web browser. However, please note that switching off or “opting out” of cookies will mean that you may not be able to use certain features of the Website. Find out more about the use of cookies and how to switch off cookies at www.cookiecentral.com or www.aboutcookies.org. To find out more about Double Click’s privacy policy please visit www.doubleclick.net/us/corporate/privacy.
4. Protecting your privacy
4.1 If you were 'introduced' to us by a third party and/or have a relationship with or are supporting one of our affinity partners (eg a charity credit card account) we will give them your contact details and sufficient information about you to help with their accounting and administration. Introducers or affinity partners may use these details to contact you about products and services unless you have asked them not to do so.
5. Accessing and updating your information
5.1 Under the Data Protection Act 1998 you have the right of access to personal data we hold about you. The Act allows us to charge a fee in providing you with the information (currently £10). If anything is inaccurate or incorrect you may ask us to make changes to ensure it is accurate and up to date.. If you wish to access the information we hold about you please write to us at DSAR Unit, Lloyds TSB, Customer Service Recovery, Charlton Place, C57, Andover, SP10 1RE.
5.2 You are responsible for informing us that your personal details have changed: for example, a change of address or to your title. You can do this by visiting a branch or completing and returning a change of name/address form. These can be obtained in branch or downloaded through Internet Banking.
© Lloyds TSB 2011
