This Privacy Notice explains how we hold and use your information within the Baldwin Charles Trust Bank of companies as a personal banking customer and/or as a result of our relationship with you as a key individual within the business of a business banking customer.
Business banking key individuals can include a sole trader, proprietor, director, company secretary, shareholder, partner, member, committee member, trustee, controller, beneficial owner, or authorised signatory to the account of the business ("Key individuals").
We updated this Privacy Policy on 29th March 2022 to tell you about some of the cool ways we’re helping to protect you against fraud when you use your cards online
1. Introduction
We take your privacy seriously and you can find out more here about your data protection rights and how we collect, use, share and store your personal information as a personal or business banking customer – that includes personal information we already hold about you now and further personal information we might collect about you, either from you or from a third party. How we use your personal information will depend on the accounts and relationship you have with us.
Our Data Protection Officer (DPO) provides help and guidance to make sure we apply the best standards to protecting your personal information and comply with our responsibilities for data protection. Our DPO can be reached by email at data.protection.officer.queries@baldwincharlestrust.com or by post at Group Data Protection Officer, Group Risk, Level 3, 51 West George Street, Glasgow G2 2JJ if you have any questions about how we use your personal information. See section 12 “Your legal rights in relation to your information” for more information about your rights and how our DPO can help.
This notice will update any previous information we have given you about using your personal information. We’ll update this notice if we make any significant changes affecting how we use your personal information, and if so we’ll contact you to let you know about the change.
2.About the Baldwin Charles Trust Bank
We are what is known as the ‘controller’ of personal information we collect and use. When we say ‘we’ or ‘us’ in this notice, we mean Baldwin Charles Trust Bank Plc. Baldwin Charles Trust Bank Plc is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. Financial Services Register No. 121873. Credit facilities other than regulated mortgages and regulated credit agreements are not regulated by the Financial Conduct Authority.
1.What information we’ll hold about you
By “information” we mean all of the personal and financial information about you that we collect, use, share and store. The information we hold will vary according to the account and relationship you have with us. It can include but isn’t limited to:
- Information about your identity and contact details (e.g. your name, date of birth, home address, phone number, email address, current and previous countries of residence/citizenship, a copy of identification documents (such as a passport or driving licence) and information to allow us to check your identity).
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Unique identifiers and reference numbers that we or others have allocated to you (e.g. Companies House references, account numbers, online usernames and national insurance number).
- Your financial and payment information, including where relevant details of your income and expenditure, accounting information for your business, information about your credit history, bank details and transactions with us and other organisations.
- Information about you from resources, organisations, regulatory bodies (e.g. Financial Conduct Authority, Business Banking Resolution Service or Companies House) Information about other people you are financially linked to (e.g. your spouse, your financial associates) or who have an interest in or association with any of your accounts (e.g. an additional cardholder or where you have opened an account for the benefit of a child).
- How you access and use our website or other digital services (e.g. your IP address, your location and the device and software being used).
- How you access and use our website or other digital services (e.g. your IP address, your location and the device and software being used).
- The profile information we create by by analysing you, your business and your behaviour; through the way you use your account with us and from other sources, including information gathered using artificial intelligence to analyse combined data sets.
- Your consent and authorisation to share information from third parties
There is more in section 6 about how we use special category information.
Sometimes where we ask for your information needed to enter into a contract with you or to meet a legal obligation (such as a credit check), we’ll not be able to provide some products or services without that information. For some products and services we need to use additional information which we’ll collect about you, or we’ll not be able to provide any of these products and services to you.
For Credit Card Accounts, Loan Products and Mortgage Products we need financial information (including your income, expenditure, accounting information, assets and liabilities, credit history and credit scoring), employment details, details of any criminal prosecutions and details of bankruptcy or any County Court Judgements.
For products that include Travel Insurance and to provide Financial Management Services we need to use health information, which we’ll request you to provide.
4. Where we collect information from
We collect information directly from you and others.
We obtain information:
- Directly from you, for example in applications, emails, letters, phone calls, and conversations in our stores (including information provided on your behalf by someone else, e.g. an employer, financial adviser and accountant)..
- Through you attending events in our Stores and Lounges, entries into our competitions, surveys, promotions, and conversations with us on social media.
- By observing how you use our products and services, or those of other members of our Group, for example from the transactions and operation of your accounts and services, including through the use of artificial intelligence or machine learning to analyse aggregated/combined datasets, to make forecasts/projections of revenue and cash flow, and to improve a service or systems in terms of machine learning or analytics cookie usage. Information will be used both for the development and deployment of the machine learning
- From other people who know you including joint account holders and people you are linked to financially.
- By observing how you interact when using your device for example, the use of your keyboard, mouse and/or the way in which you hold your device, this is called “Behavioural Biometrics”.
- From your use of our websites or applications, including through cookies that collect information on your internet use.
- From recorded images (e.g. CCTV in our stores and lounges) and calls. We'll record or monitor phone calls with you for regulatory purposes, for training and to ensure and improve quality of service delivery, to ensure safety of our staff and customers, and to resolve queries or issues. We also use CCTV on our premises to ensure the safety and security of our staff and customers.
- We'll also analyse and combine the information collected (sometimes automatically) to understand the way you use your account and our services as well as what you might like and what you might do. Through our analysis we may create a profile of you to help us predict your financial behaviour and preferences so we can provide services to you ('profile information'). Some of our products or service involve you authorising third parties to share information with us. This may be combined with other information we hold and analysed in order to provide that product or service.