Data Protection Notice – Additional information

GDPR is the EU General Data Protection Regulation which comes into effect from 25 May 2018. It sets out a series of new EU laws concerning how data is processed and used. The objective of the regulation is to strengthen and standardise data protection laws for all EU citizens. These regulations will apply to any organisation that controls and/or processes data on behalf of an individual or group of individuals. Those responsible for adhering to these regulations include employees of the organisation, contractors, consultants, agents and third parties who have access to data either directly or indirectly.

We have always appreciated your trust in us to collect, process and protect your information. As a data controller and processor of your personal data, we will continue to

• develop on our strong risk culture by acting responsibly and putting your security at the front of our priorities;
• manage our controls, processes and systems to improve our level of customer service while providing you with the assurance that your information is safe and secure; and
  
• conduct our business in a fair and transparent way and ensure we minimise the risk of unfair outcomes for our customers and the effect on their data rights and freedoms.
  

Our Data Protection Notice and the additional information on our website, explains how we collect personal information about you, how we use it and how you can interact with us about it.

When we talk about ‘AIB’, ‘we’, ‘us’ and ‘our’ we are referring to AIB Group (UK) p.l.c. which includes AIB (NI), Allied Irish Bank (GB) and Allied Irish Bank (GB) Savings Direct, and AIB Group which refers to Allied Irish Banks, p.l.c., its subsidiaries, affiliates and their respective parent and subsidiary companies. For more information about our group of companies, please visit www.aibgroup.com.

We share your information within AIB Group to help us provide our services, comply with regulatory and legal requirements, and improve our products.

We share your information within AIB Group to help us provide our services, comply with regulatory and legal requirements, and improve our products.

For example, the European Banking Authority’s guidelines on Loan Origination and Monitoring require us to have a single, consistent view of our borrowers’ assets and liabilities throughout the AIB Group. When assessing and monitoring loans, we will access a Single Customer View of accounts our customers may have across the AIB Group, including AIB (ROI and UK), EBS and Haven. European Banking Authority’s guidelines on connected clients requires that we take a holistic view of customer connections for assessing connected facilities and exposures.  Your data may be used in the assessment of another AIB Customer where there is a customer connection.  The account information that’s available will help us to more efficiently assess applications for new credit facilities, for example new loans or credit cards, as well as support our ongoing review of credit arrangements.

The Group entity you are engaging with remains the controller of your information and will facilitate you exercising any of your data protection rights. The Group entities together act as joint controllers for the Single Customer View and Connected Clients.  

Our Data Protection Officer oversees how we collect, use, share and protect your information to ensure your rights are fulfilled. You can contact our Data Protection Officer at UKDPO@aib.ie or by writing to them at: Data Protection Officer, AIB Group (UK) p.l.c., First Trust Centre, 92 Ann Street, Belfast, BT1 3HH.

We collect personal information from you, for example when you:

• open an account;
• when reviewing your credit facility or a facility you have a connection to
• make a deposit;
• apply for products and services;
• use your credit or debit card;
• complete transactions; or 
• look for advice.

We also collect information through our website, apps, social media, discussion forums, market research and our CCTV footage.

We may source information about your assets or loans from reliable third party sources. For example, when you apply for a loan against a property, we will collect the energy rating information about the property from an online register (e.g. the Energy Performance of Buildings Register).

If you are a sole trader, or in a business partnership, we may also collect information about your company from your website(s). An example of this could be where we collect Environmental, Social and Governance information from your company’s published sustainability report.

This is some of the information we collect and hold about you when applying for and using our products and services:

Under GDPR, there are special categories that require additional safeguards for processing. In some instances, we will require this information for processing or it may be volunteered by you. These data types and the reason we collect them are:

We use information about you to:

• provide relevant products and services;
• identify ways we can improve our products and services;
• maintain and monitor your products and services; 
• When assessing or reviewing your facilities in respect of yourself or whether part of a connection to other customers;
• protect your interests, and the interests of others; and
• decide and recommend how our products and services might be suitable for you.

To provide our products and services under the terms and conditions we agree between us, we need to collect and use personal information about you. If you do not provide this personal information, we may not be able to provide you with our products and services.

The European Banking Authority’s guidelines on Loan Origination and Monitoring require us to have a single, consistent view of our borrowers’ assets and liabilities throughout the AIB Group. When assessing and monitoring loans, we will access a Single Customer View of accounts our customers may have across the AIB Group, including AIB (ROI and UK), EBS and Haven. European Banking Authority’s guidelines on connected clients requires that we take a holistic view of customer connections for assessing connected facilities and exposures.  Your data may be used in the assessment of another AIB Customer where there is a customer connection.  The account information that’s available will help us to more efficiently assess applications for new credit facilities, for example new loans or credit cards, as well as support our ongoing review of credit arrangements.

We analyse the information that we collect on you through your use of our products and services and on our social media, apps and websites. This helps us understand your financial behaviour, how we interact with you and our position in a market place. Examples of how we use this information include helping protect you from financial crime, offering you products and services, personalising your experience and meeting our regulatory requirements.

We may report trends we see to third parties. These trend reports may include information about activity on devices, for example mobile phones, ATMs and self-service kiosks, or card spend in particular regions or industries. When we prepare these reports, we group customers’ information and remove any names. We do not share information in these reports that can identify you as a customer, such as your name, or account details.

We sometimes use technology to help us make decisions automatically. For example, when you apply for a loan online. Before we make a decision, we automatically score the information you give us, any information we already hold about you, and any information we may get from other sources.  See 'Automated Decision Making' section for further information.

All of our processing must be supported by a lawful basis, as discussed in our 'Meeting our legal and regulatory obligations' section. 

To use your information lawfully, we rely on one or more of the following legal bases:

• performance of a contract;
• legal obligation;
• our legitimate interests;
• your consent;.
• protecting the vital interests of you or others; and
• public interest.

To help you better understand where these lawful bases may apply, these are some examples for each lawful basis. In some cases, the same information is processed under more than one lawful basis:

To meet our regulatory and legal obligations, we collect some of your personal information, verify it, keep it up to date through regular checks, and delete it once we no longer have to keep it. We may also gather information about you from third parties to help us meet our obligations.

In order to process your application, we will perform credit and identity checks on you with one or more credit reference agencies (“CRAs”). Where you take banking services from us we may also make periodic searches at CRAs to manage your account with us.

To do this, we will supply your personal information to CRAs and they will give us information about you. This will include information from your credit application and about your financial situation and financial history. CRAs will supply to us both public (including the electoral register) and shared credit, financial situation and financial history information 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 exchange 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 such time as 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 at each of the three CRAs websites – clicking on any of these three links will take you to the same CRAIN document:

Callcredit : http://www.callcredit.co.uk/crain
Equifax : https://www.equifax.co.uk/crain
Experian : http://www.experian.co.uk/crain

Who are the Credit Reference Agencies and how can I contact them?

There are three main credit reference agencies in the UK who deal with people’s personal data.

Each is regulated by the Financial Conduct Authority (“FCA”) and authorised to conduct business as a credit reference agency.

Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

Our contact details can be found in the ‘Contact us’ section of our website.

What we process and share

The personal data you have provided, we have collected from you, or we have received from third parties may include your:

• name
• date of birth
• residential address and address history
• contact details such as email address and telephone numbers 
• financial information
• employment details 
• identifiers assigned to your computer or other internet connected device including your Internet Protocol (IP) address
• vehicle details
  

When we and fraud prevention agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, in order to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

Fraud prevention agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

Automated decisions

As part of the processing of your personal data, decisions may be made by automated means. This means we may automatically decide that you pose a fraud or money laundering risk 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.

You have rights in relation to automated decision making: if you want to know more please contact us using the details above.

Consequences of processing

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. If you have any questions about this, please contact us on the details above.

Data transfers

Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing.

Your rights

Your personal data is protected by legal rights, which include your rights to:

• object to our processing of your personal data;
• request that your personal data is erased or corrected;
• request access to your personal data.

For more information or to exercise your data protection rights please, please contact us using the contact details above.

If you are unhappy about how your personal data has been used please refer to our complaints policy.

You also have a right to complain to the Information Commissioner's Office at www.ico.org.uk which regulates the processing of personal data.

Financial institutions in the UK are required under legislation which incorporates the US Foreign Account Tax Compliance Act (FATCA) and the Organisation for Economic Cooperation and Development (OECD) Common Reporting Standard (CRS) into UK law to seek answers to certain questions for purposes of identifying accounts that are reportable to HMRC for onward transmission to tax authorities in relevant jurisdiction(s).

Financial institutions in UK are required to seek answers to questions regarding tax residency. If customers do not provide all of the information requested, we may not be able to proceed with opening the new account until the relevant information is provided and we may be obliged to include the account(s) detail in the annual FATCA return and CRS return to HMRC.

Please note that AIB (NI) / Allied Irish Bank (GB) is unable to offer taxation advice. For tax related questions and/or further information please contact your professional tax advisor or HMRC on https://www.gov.uk/government/collections/automatic-exchange-of-information-agreements

Sometimes we need your consent to use your personal information. For example, when we use sensitive personal information (known as ‘special category information’ under GDPR) about you, such as medical or biometric data, we ask for your explicit consent.

We have controls to ensure that you are informed when making your decision and that you are aware that you can remove your consent at any time by contacting us. Our consent requests are built on the following principles:

• Positive Action - Clear affirmative action is required. We will no longer use pre-ticked boxes, imply or assume consent in the event of no positive action from you.

• Free will – Your consent must be freely given and not influenced by external factors.

• Specific – We will be clear on what exactly we are asking your consent for.

• Recorded – We will keep a record of your consent and how it was obtained.

• Can be withdrawn at any time – We will stop data processing requiring your consent at any time you make valid request.

For direct marketing, we need your consent to make you aware of products and services which may be of interest to you. We may make you aware of these by phone, post, email, text or through other digital media.

You can decide how you would like to be contacted and if you are happy to accept this marketing, by opting in or out when you apply for new products and services. You can also change your options at any time by contacting us.

As part of our direct marketing, we analyse the information that we collect on you through your use of our products and services and on our social media, apps and websites. This helps us understand your financial behaviour, how we interact with you and our position in a market place. This enables us to personalise your experience and provide you with the most suitable products and services.

If we ever contact you to get your feedback on ways to improve our products and services, you also have the choice to opt out. 

We protect your information with security measures under the laws that apply and we meet international standards. We keep our computers, files and buildings secure.

Please visit the Fraud and Security Centre, where you can read more information on how we protect your privacy and your personal data.

In addition to our technical controls, our Data Protection Officer oversees how we collect, use, share and protect your information to ensure your rights are protected and fulfilled. Our Data Protection Officer advises on how we can best understand risks to your data rights and freedoms, implements processes to protect these and has responsibility to report to the Data Protection Authorities if we are not meeting our obligations.

When you contact us to ask about your information, we may ask you to identify yourself. This is to help us protect your information.

To meet our legal, regulatory and business requirements, we hold your information while you are a customer and for a period of time after that. To help you understand how long we hold some of your data for, we have summarised some of our key retention schedules below.

Please note that these retention periods are our policy but are also subject to external considerations, which may require us to hold the information for a longer period. For example, we must meet minimum retention standards for our legal obligations. Our regulators, can also request we retain data for longer than our internal schedules. We must do this to protect both of our interests.

We continuously assess and delete data to ensure it is not held for longer than necessary.

Sometimes we share your information with third parties.

For example to:

• provide products, services and information;

• analyse information;

• research your experiences dealing with us;

• collect debts;

• sell your debts;

• sell whole or part of our business;

• prevent financial crime;

• help trace, investigate and recover funds on your behalf;

• trace information; and

• protect both our interests.

Third parties we may share information with can include:

• Estate agencies

• Credit reference agencies

• Fraud prevention agencies

• Company search databases

• Regulatory bodies; including the Financial Conduct Authority, Prudential Regulation Authority, Competition and Markets Authority, Lending Standards Board, Financial Ombudsman Service, Information Commissioner’s Office and the Central Bank of Ireland.

• Companies we have a joint venture or agreement to work with

• Insurance companies

• Government bodies including HM Revenue & Customs

• Businesses that introduce you to us or we introduce you to

• Cards/transaction processing

• Market research companies

• Financial advisors

• Debt collection agencies

• External consultancy firms including Legal, Accountancy, Compliance and other Professional Services

• Any entity you request your data to be shared with

We require that these third parties provided sufficient guarantees that the necessary safeguards and controls have been implemented to ensure there is no impact on your data rights and freedoms.

We also have to share information with third parties to meet any applicable law, regulation or lawful request. When we believe we have been given false or misleading information, or we suspect criminal activity we must record this and tell law enforcement agencies, which may be either in or outside the UK.

We may transfer your personal information outside of the European Economic Area (EEA) to help us provide your products and services. We expect the same standard of data protection to be applied outside of the EEA to these transfers and the use of the information, to ensure your rights are protected.

Details on your information rights, how we can help ensure that you are aware of these rights, how you can exercise these rights and how we intend to deliver on your requests can be found here.

These rights include:

• Right of Access to information (Subject Access Request)
• Updating and correcting your personal details
• Right to restrict processing
• Right to object to processing
• Deleting your information (Right to be forgotten)
• Moving your information (Right to Portability)
• The right to lodge a complaint with a supervisory authority

You can change your mind wherever you have given us your consent, and you can request that we no longer process data we require your consent for, such as for direct marketing or processing your sensitive information, such as medical or biometric data.

We sometimes use technology to help us make decisions automatically. We use information provided directly by you, any information we may hold about you, and information from third parties, to make decisions that are efficient, quick, and fair based on the information provided.

You have the right to object to automated decision making. You can request that a person is involved in an automated decision that affects you directly. Please see ‘Your Rights ’ section for further details.

When you apply for loan products, we use multiple data sources to understand your ability to repay the loan. This ensures we lend responsibly.

We use the information provided by you on the applications and information from third parties such as credit reference agencies.

The information we process for automated decisions include:

• Income
• Financial position
• Transaction history
• Employment details
• Discretionary spending
• Credit rating
• Your other loans, mortgages and products
  

Analysis of this information helps us assess whether you can meet the loan payments. The initial affordability decision is completed by our automated decision engines. If you are declined based on the automated criteria, you can ask that your application is assessed manually by one of our staff. 

If you have a complaint about the use of your personal information, please let a member of staff in your branch know, giving them the opportunity to put things right as quickly as possible. If you wish to make a complaint you may do so in person, by phone, in writing and by email. We will fully investigate all the complaints we receive. You may complain through our contact centre, our branches, our website, by phone, by email or in person at your branch. We ask that you supply as much information as possible to help us resolve your complaint quickly.

You can also contact the Information Commissioner’s Office (ICO) at the below details:

• Visit their website at ico.org.uk 
• Email at: casework@ico.org.uk
• Phone on: 0303 123 1113 
• Write to: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

We will make changes to our Data Protection Notice from time to time, particularly when we change how we use your information, and change our technology and products. You can always find an up-to-date version of our Notice on this website, on display at your local branch, or you can ask us for a copy.