How personal information is used
13. 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 you with 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 personal information with other companies in Lloyds Banking Group.
This means official bodies that include:
- Central and local government
- HM Revenue & Customs, regulators and other tax authorities
- UK Financial Services Compensation Scheme and other deposit guarantee schemes
- Law enforcement and fraud prevention agencies.
Banking and financial services
Outside companies we work with to provide services to you and to run our business.
- Agents, suppliers, sub-contractors and advisers
These are types of firm that we use to help us run accounts, policies and services.
- Agents who help us to collect what is owed to us
- Credit reference agencies (such as Callcredit, Equifax and Experian)
- Someone linked with you or your business’s product or service.
This could mean a joint account holder, trustee, or fellow company director.
- Other financial services companies (to help prevent, detect and prosecute unlawful acts and fraudulent behaviour)
- Independent Financial Advisors (if you have one)
This could be someone who you, your employer, or product owner have selected to advise on things like pensions or life assurance.
- Price comparison websites and similar companies
We only do so if you buy something from us through such a company. We only share details needed to confirm what you have bought, to fulfil our own contract with the company.
- Employers (for instance, to confirm your identity if we ask for a mortgage reference)
- Companies you ask us to share your data with
This is to do with something called Open Banking, which gives you more freedom and control to use your own banking data. It can make it easier for you or your business to shop around for products like credit cards, savings and current accounts.
We share personal information with insurance industry companies to process claims and help reduce fraud. We do that in these ways:
- If you apply for insurance through us, we may pass your personal or business details to the insurer.
- If you apply for insurance with us as the insurer, we may share your personal or business details with reinsurers.
- If you make an insurance claim, information you give to us or the insurer may be put on a register of claims. This will be shared with other insurers, our agents, suppliers and sub-contractors. In some cases we may also share it with our business partners, if you also have a relationship with them.
Other services and schemes
These are organisations that we may need to share your personal information with, because of what you can do with the product or service you have with us.
- If you have a debit, credit or charge card with us, we will share transaction details with companies which help us to provide this service (such as Visa and Mastercard).
This is needed to keep your account balance and statements up to date, for example.
- If you use direct debits, we will share your data with the Direct Debit scheme.
- If you have a product which has a loyalty scheme like Avios or Everyday Offers, we will share your data with that scheme.
- If you have a product with benefits such as travel insurance or discount offers, we will share your data with the benefit providers. We may also share it with other companies involved in how you use the service (such as a private car park operator).
- If you have a secured loan or mortgage with us, we may share information with other lenders who also hold a charge on the property (For example, the other party in a shared ownership scheme)
Outside companies we use to help grow and improve our business.
- Companies we have a joint venture or agreement to co-operate with (such as a store or car dealership or broker offering finance deals through us)
- Organisations that introduce you to us
This might be a store or car dealership that offers finance deals through us, or a price comparison website.
- Market researchers
These firms may get in touch with you on our behalf to ask you for your opinions and feedback. Sometimes these firms will combine what you tell them with data from other sources to study it. The will use this to produce reports and advice that help us understand our customers’ point of view, so that we can improve the way we work as a business.
- Advisers who help us to come up with new ways of doing business.
This might be a legal firm, IT supplier or consultancy.
- Advertisers and technology providers that you use (such as websites you visit, social networks, and providers of apps and smart devices)
If you allow it, these firms display messages to you and others about our products and services and use personal information to make sure these messages are relevant for you.
Company mergers,takeovers and transfers of products or services
We may also share your personal information if the ownership of products or services or the make-up of Lloyds Banking Group changes in the future:
- We may choose to sell, transfer, or merge parts of our business, or our assets, including products or services. Or we may try to bring other businesses into Lloyds Banking Group.
This is sometimes called Mergers & Acquisitions or ‘company takeovers’.
- During any such process, we may share your data with other parties involved. We’ll only do this if they agree to keep your data safe and private.
- If the change to our Group happens, then other parties may use your data in the same way as set out in this notice.
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 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.
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14. How we work out what marketing you receive
We use marketing to let you know about products, services and offers that you may want from us. This section tells you how we decide what marketing to show or send you. It also explains how we work out what you may be interested in.
We may use your personal information to make decisions about what products, services and offers we think you may be interested in. This is what we mean when we talk about ‘marketing’.
We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’. That is when we have a business or commercial reason to use your information. It must not conflict unfairly with your own interests.
The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from outside organisations we work with. We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
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 you allow it, we may show or send you 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 you set. 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 you do, you will still see some marketing but it will not be tailored to you. See our Cookies policy for details about how we use this data to improve our websites and mobile apps.
Whatever you choose, you'll still receive statements and other important information such as changes to your existing products and services.
We do not sell the personal information we have about you to outside organisations.
We may ask you to confirm or update your choices, if you take out any new products or services with us in future. We will also ask you to do this 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.
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15. How we use your information to make automated decisions
Here we tell you how we use automated systems to make decisions about you and your money. We also explain the rights you have to challenge decisions made this way.
We sometimes use systems to make automated decisions about you or your 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 you now or in the future, or the price that we charge you 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:
We may decide what to charge for some products and services based on what we know. For instance, if you use our online mortgage calculator, it will use the personal financial details you put in to estimate the kind of mortgage we may offer you. If you apply for insurance, we will compare what you tell us with other records to work out how likely you are to make a claim. This will help us to decide whether to offer you the product and what price to charge you.
Tailoring products, services, offers and marketing
We may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products, services and offers for different customer segments, and to manage our relationships with them. It also helps us tailor the marketing that individuals receive or are shown on our own and other websites and mobile apps, including social media.
We use your personal information to help decide if your personal or business accounts may be being used for fraud or money-laundering. We may detect that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. If we think there is a risk of fraud, we may stop activity on the accounts or refuse access to them.
When you open an account with us, we check that the product or service is relevant for you, based on what we know. We also check that you or your business meet the conditions needed to open the account. This may include checking age, residency, nationality or financial position. It may mean we cannot offer you the account you want.
We use a system to decide whether to lend money to you or your business, when you apply for credit such as a loan or credit card. This is called credit scoring. It uses past data to assess how you’re likely to act while paying back any money you borrow. This includes data about similar accounts you may have had before.
Credit scoring uses data from three sources:
- Your application form
- Credit reference agencies
- Data we may already hold.
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 you credit, or allow you to take another product or service.
You can object to an automated decision we have made, and ask that a person reviews it.
If you want to know more about these rights, please contact us.
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16. Credit Reference Agencies (CRAs)
This section explains how we work with outside companies to decide whether to lend you money through products like credit cards or loans. It explains what we do and why we do it.
We carry out credit and identity checks when you apply for a product or services for you or your business. We may use Credit Reference Agencies to help us with this.
If you use 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 data we exchange can include:
- Name, address and date of birth
- Credit application
- Details of any shared credit
- Financial situation and history
- Fraud prevention information
- Public information, from sources such as the Electoral Register and Companies House.
We’ll use this data to:
- Assess whether you or your business is able to afford to make repayments
- Make sure what you’ve told us is true and correct
- Help detect and prevent financial crime
- Manage your accounts with us
- Trace and recover debts
- Make sure any offers are relevant for you.
We will go on sharing your personal information with CRAs for as long as you are a customer. This will also include details of funds going into the account, and the account balance. If you borrow, it will also include details of your repayments and whether you repay in full and on time. We will also tell the CRAs when you settle your accounts with us. The CRAs may give this information to other organisations that want to check your credit status.
When we ask CRAs about you or your business, they will 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:
- Who they are
- Their role as fraud prevention agencies
- The data they hold and how they use it
- How they share personal information
- How long they can keep data
- Your data protection rights.
Here are links to the information notice for each of the three main Credit Reference Agencies:
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17. 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 and terrorist financing.
We may need to confirm your identity before we provide products or services to you or your business. This may include carrying out fraud checks at the point of sale.
Once you have 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:
- Registered Fraud Prevention Agencies (FPAs)
- Other agencies and bodies acting for the same purpose
- Industry databases used for this purpose
Throughout our relationship with you, we and these organisations exchange data between us to help prevent, deter, detect and investigate fraud and money-laundering.
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 data. Even then, it must not unfairly go against your interests.
We will use the information to:
- Confirm identities
- Help prevent fraud and / or money-laundering
- Fulfil any contracts you or your business has with us.
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
These are some of the kinds of personal information that we use:
- Date of birth
- Residential address
- History of where you have lived
- Contact details, such as email addresses and phone numbers
- Financial data
- Whether you have been a victim of fraud
- Data about insurance claims you have made
- Data relating to your or your businesses products or services
- Employment details
- Vehicle details
- Data that identifies computers or other devices you use to connect to the internet. This includes your Internet Protocol (IP) address.
Automated decisions for fraud prevention
The information we have for you or your business is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
We and other organisations acting to prevent fraud may process your personal information in systems that look for fraud by studying patterns in the data. We may find that an account or policy is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. Either of these could indicate a risk that fraud or money-laundering may be carried out against a customer, the bank or the insurer.
How this can affect you
If we or an FPA decide there is a risk of fraud, we may stop activity on the accounts or block access to them. FPAs and cross-industry organisations may also keep a record of the risk that you or your business may pose.
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
FPAs and other organisations we share data with for these purposes may send personal information to countries outside the UK and European Economic Area (‘EEA’). When they do, there will be a contract in place to make sure the recipient protects the data to the same standard as the EEA. This may include following international frameworks for making data sharing secure.
Here is the web page for the information notice for one of the main Fraud Prevention Agency we use:
CIFAS - www.cifas.org.uk/fpn
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18. Sending data outside of 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:
- Follow your instructions.
For example, if you book a hotel in Australia with your Lloyds Banking Group card we will send your details necessary to fulfil that payment to the hotel’s bank.
- Comply with a legal duty.
For example, we share information about US citizens with the US tax authority.
- Work with our suppliers who help us to run your accounts and services.
If we do transfer your personal information outside the UK and EEA to our suppliers, we will make sure that it is protected to the same extent as in the UK and EEA. We’ll use one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Learn more on the European Commission Justice website.
- Put in place a contract with the recipient that means they must protect it to the same standards as the UK and EEA. Read more about this here on the European Commission Justice website
- Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the UK and EEA. You can find out more about data protection on the European Commission Justice website.
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