EXL Private Bank is a data controller registered with the Information Commissioner under number CSN7963800. The Data Protection Regulations require us to process your data fairly and lawfully and in line with the principles of Data Protection.
To provide you with bank accounts and other products and services (our contractual obligations), we need to collect, use, share and store personal information about you and your transactions (“Your Information”). In addition to our contractual obligations, we collect and hold your personal information for the following reasons:
- regulatory requirements (or legal rights);
- with your consent (for purposes which are specified at the time of taking your consent).
A. This section explains how we will use Your Information:
“Your Information” includes information which we
- obtain from you or third parties, such as employers, joint account holders, credit reference agencies, fraud prevention agencies or other organizations when you apply for an account with us or for any of our other products or services, or which you or they give to us at any other time; or
- learn from the way your accounts with us are administered and managed, from the transactions made such as the date, amount, currency and the name and type of supplier (for example, supermarket services, medical services, transactions in assets, retail services) and from the payments which are made to and from your accounts with us.
In general, the data we collect from you relates to:
- Your identity;
- Credit history of self or associated persons;
- Any fraudulent association or history of self or related persons;
- Any links to political exposures or status as politically exposed persons;
- Any sensitive information that you may provide us knowingly or unknowingly, whether related or unrelated to the products or services we provide.
In case you provide personal and financial information about others (such as dependents, other family members, or a joint account holder), you confirm that you have their consent, or that you are otherwise entitled to provide this information to us and for that information to be used following these Terms and Conditions.
How We Use Your Information
We, together with other companies associated with us, will use your information (if required) to process and store your application, manage your accounts, give you statements and provide our services and products, to make credit decisions about you (and anyone to whom you are financially linked) for assessment and analysis (including credit and behavior scoring, market and product analysis), to prevent and detect fraud, money laundering, and other crime, to carry out regulatory checks, to meet our obligations to any relevant supervisory authority, to develop and improve our services to you, to recover debts and to protect our interests.
To comply with legal requirements, we may provide your information to agencies like HMRC, CIFAS, Anti-fraud agencies, money laundering enforcement, and such as agencies.
Data used for Marketing Purposes
We may use your information to inform you by letter, telephone, fax, text messages, email and other electronic methods about products and services (including those of others) which may be of interest to you. However, we will do this only after taking your specific consent (or explicit opt-in) by informing you of the purpose for which we are seeking your permission.
You have the right to withdraw your consent at any time if you do not want us to use your personal information for the purpose for which it was obtained.
“Your Information” we may share with Third Parties
We may share Your Information with the following third parties, wherever located:
- with our parent company
- our partners and companies and organizations that provide services to us or assist us or act as our agents including but not limited to sub-contractors and professional advisors;
- anyone to whom we may transfer our rights and obligations under any agreement we have with you;
- your advisers (including but not limited to accountants, lawyers or other professional advisors) who are authorized by you;
- credit reference agencies and fraud prevention agencies;
- where it is our duty to do so, or if law or regulation allows us to do so.
Other than the reasons stated above, Your Information
shall not be disclosed to anyone unless the disclosure is made with your consent.
We will contact you if we intend to further personal process data for a different purpose to which it was collected initially.
Transfer of Your Information Overseas
Your information may be transferred to another company of EXL Private Bank group of companies or to a service provider or agent in another country (including countries outside the EEA) to process your data for the purposes as stated in condition A above. We will make sure that our group companies, service providers, or agents agree to apply the same levels of protection as we are required to as per UK Regulations, and this we do by enforcing through contractual obligations on the service providers to whom we may outsource such activities.
Retention of information:
The personal information we possess about you will be kept with us as follows:
- Till the time your relationship with us continues;
- After the termination of your relationship, we will continue to hold the personal information for a period as per our internal policy guidelines to ensure that we meet our obligations to the legal bodies and the Regulators;
- To defend contractual rights arising from such relationships (in the UK the period is six years after the customer relationship has ended);
- Where the data is not required due to relationships not established or the information is no longer needed due to other reasons, the data will be retained only for a reasonable time, which is decided by our internal policy, beyond which processes are in place to erase the data.
Credit Reference Agencies and Fraud Prevention Agencies
We may give Your Information to and receive information from credit reference agencies and fraud prevention agencies for meeting regulatory requirements.
Other organizations and we may access your information to prevent and detect fraud, money laundering, and other crimes to make credit assessments and decisions about credit-related services to enable us to manage and make decisions about your accounts, insurance policies, and insurance claims and to recover debts.
Any information held about you by the credit reference agencies may already be linked to records relating to your partner or members of your household where a financial “association” has been created. Any inquiry we make at a credit reference agency may be assessed concerning any associated records. Another person’s history will be associated with yours when:
- you make a joint application;
- you advise us of a financial association with another person; or
- if the credit reference agencies have existing linked or “associate” records.
This “association” will be taken into account in all future applications by either or both of you and shall continue until one of you applies to the credit reference agencies and is successful in filing a “disassociation”.
Credit reference agencies keep a record of our inquiries and may record, use, and give out the information we give them to other financial institutions, insurers, and other organizations. If false or inaccurate information is provided or fraud is suspected, details may be passed to fraud prevention and credit reference agencies. Law enforcement agencies may access and use this information. The information recorded by fraud prevention agencies may be obtained and used by organizations in several countries, including the UK. We can provide the names and addresses of the credit reference and fraud prevention agencies we use if you would like a copy of Your Information held by them. Please contact us in writing to our Head Office or branch offices if you want to receive such details.
To refer to more information on how your data may be used at present by Credit Reference and related agencies whose services we utilize, please refer to the following link:
Right to receive a copy of Your Information
You can ask for a copy of your information by writing to us. You have a right to know the details of the information we have, the reason for holding it, how long we plan to keep it, how the data was acquired, whether any automated decision making was involved, and it was or will be processed outside the EEA. We will provide a copy of the information we possess if you require so.
Where any of your data we hold is incorrect, you have the right to tell us to correct it promptly. If your information is incomplete, you can ask us to correct this too. We expect you to notify us at the earliest possible occasion about any change in address or other contact details.
Right to be forgotten –
You may have a right to have some or all of the information we hold about you deleted. However, we are required to retain many records even after you close your account, as already mentioned. Our complying with your request will be subject to our fulfilling our obligations as a Bank to such legal/regulatory requirements.
You would be entitled to receive some of your information from us electronically, in certain circumstances. We can either pass the information to you or another person or business as you desire.
You have a right to ask us to restrict how we use your data in some instances where you think we hold incorrect information, and we may be using it for purposes not intended at the time you provided us with such information.
Automated decision-making –
We may use automatic systems to make decisions about your eligibility for a particular account or products, and to carry out credit and fraud prevention checks. Automated decision making may typically be based on the information you give us, which we check against different parameters to determine whether you meet the eligibility criteria for the product intended. Where the outcome of such decision making goes against you, you will be able to contest the decision, give your views, and make sure there is proper human involvement.
If you consent to us using your information, you have the right to withdraw that consent at any time.
If you want to exercise the rights mentioned above, you may do so by contacting the customer service team.
You may contact the Data Protection Officer as per details given below: