Welcome to Swansea Building Society's (SBS) privacy notice.
SBS respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how SBS collects and processes your personal data through your use of this website.
It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
SBS is the controller and responsible for your personal data.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full details are:
Full name: Swansea Building Society
Name or title of DPO: Catherine Griffiths
Email address: firstname.lastname@example.org
Postal address: 11-12 Cradock Street, Swansea, SA1 3EW
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. The contact details for this purpose are our Head Office in Cradock Street or any of our branches. If you were introduced to us by a broker or other intermediary, you should contact them separately. In some cases when you exercise rights against us under data protection laws we may need to inform the broker or other intermediary but this will not always be the case.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes salary and details of income, savings, expenditure, tax position and details about your existing borrowings.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We will sometimes also collect special categories of personal data such as about your health or if you are a vulnerable adult.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). 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.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when for instance you apply to open an account or when you contact us.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Credit reference agencies
- Disclosure and Barring Service
- Your employer
- Your landlord
- Other lenders
- Debt recovery and/or tracing agents
- Police and law enforcement agencies
- Publicly available directories and information
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Lawful basis for processing|
To perform our contract with you or for taking steps prior to entering into it, including:
(a) administering and managing your accounts, updating your records, tracing your whereabouts, recovering debt in relation to a mortgage product
(b) sharing your information with other payment providers
(c) managing your mortgage or savings accounts
(d) assessing applications for employment with us.
||Performance of a contract with you|
To comply with our legal obligations as a regulated building society, such as:
(a) establishing, defending and enforcing our legal rights
(b) activities relating to the prevention, investigation and detection of crime.
(c) assessing applications for employment with us
(d) carrying out identity checks, anti money laundering checks
(e) dealing with requests from you to exercise your rights under data protection laws
(f) to process information about a crime or offence
(g) sharing your personal information with certain organisations (see paragraph 5 below)
||Necessary to comply with our legal obligations|
To undertake the following:
(a) administer and manage your accounts, update your records, tracing your whereabouts, recovering debts in relation to a mortgage or savings product
(b) to test the performance of our products, services and internal processes
(c) to adhere to guidance and best practice under the regimes of governmental and regulatory bodies
(d) for management and audit of our business operations including accounting
(e) to carry out searches at credit reference agencies pre application
(f) to carry out monitoring and to keep records
(g) to administer our good governance requirements such as internal reporting and compliance obligations or administration required for AGM purposes
(h) for market research and analysing and developing statistics
(i) for direct marketing communications
(j) sharing your personal information with certain organisations (see paragraph 5 below)
||Necessary for our legitimate interests|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||
||Necessary for our legitimate interests|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||
||Necessary for our legitimate interests|
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Keeping in contact with you
We may use your home address, phone numbers and email address to provide you with important information about your accounts. We will never ask you to reveal your password or personal information by email.
In addition, we may use your contact details to contact you with marketing information about our other products and services which may be of interest to you. Currently, we only do this by post. You will have the opportunity to opt out of receiving such marketing information when you first provide your details to us, and you can change your mind at any time by contacting our DPO.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Guarantors (if applicable)
- Joint account holders, trustees and beneficiaries and any person with power of attorney over your affairs
- Other payment services providers
- Other account holders or individuals
- Broker or intermediary who introduced you to us
- Our legal or other professional advisers, auditors and actuaries
- Financial institutions
- Law enforcement agencies
- Organisations that provide services to us
- Credit reference agencies
- Buyers and their professional representatives as part of any restructuring or sale of business or assets
- Market research organisations
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We are based in the UK and your personal information is stored within the Economic European Area (EEA). We do not transfer your personal information outside the EEA other than in exceptional circumstances, where a problem is identified with your account and that we cannot fix ourselves. We use a service provider based in the EEA to administer customer account records and, where such a problem arises, your personal information may be accessed by a subsidiary company of our service provider, which is based in India and provides IT support services. We have put in place measures to ensure that your personal information is protected if it is required to be accessed from outside the EEA.
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.
How long will you use my personal data for?
We will generally hold your information for the whole time that you have an account with us, and for a period of six years after your account is closed. In some circumstances we may keep your information for longer than this, for instance where we are required by law to do so or where we need to retain your information to defend or exercise our legal rights. We may also retain transactional history for statistical research and reporting reasons.
Where the personal information is not related to an account (for instance if you have enquired about our services but have not opened an account) we will generally only keep your information for the time it takes to deal with your enquiry and for a period of 12 months.
Your legal rights
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data.
- The right to be informed
We are required to be transparent with you about the processing that we do with your personal information. This is why we have a privacy notice.
- The right to request correction of your personal data
We are required to correct your personal information if it is accurate or if personal information is incomplete. If we have disclosed the personal information in question to other organisations, we must inform them of the correction where possible.
- The right to request erasure of your personal data
This right is not absolute. It only applies in certain circumstances and, where it does not, we will tell you at the time of your request. We will not be able to comply if we are required to keep your personal information in order to comply with a legal obligation or to exercise or defend claims.
- The right to request access to the personal information held about you.
This is known as a subject access request. It enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- The right to object to processing of your personal data.
You have the right to object to our processing of your personal data where it is based on our legitimate interest, where it is processed for direct marketing or where it is processed for the purpose of statistics.
- The right to request restriction of processing your personal data
This right enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- The right to request a transfer of your personal data
This right only applies where personal information is being processed based on your consent or for performance of a contract and is carried out by automated means.
- The right to withdraw consent at any time
This right is applicable when we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of these rights against the credit reference agencies or a broker or other intermediary, you will need to contact them separately.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at email@example.com
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.