Virgin Money Privacy Policy

• Credit reference agencies (e.g. Experian) and fraud prevention agencies (e.g. CIFAS).
• Payment card networks (e.g. MasterCard).
• Price comparison websites.
• Retailers.
• Insurance companies.
• Advertisers, Social media networks and companies that do market research, statistical and behavioural analysis (e.g. Google and Facebook).
• The Government and their agencies (e.g. HM Revenue & Customs, Financial Conduct Authority, Business Banking Resolution Service, The British Business Bank and Companies House).
• Public records (e.g. the electoral roll and other public sources including internet searches).
• Other companies that provide a service to us (e.g. surveyors and lawyers).
• Marketing Services Providers - These are companies that collect personal data from a number of sources for the purposes of creating profiles of customer groups.
• Other third parties who have authorisation to share information with us.

The law requires us to verify the identity of our new customers and for business customers these include verification of Key Individuals of such customers. The law also requires us to re-verify the identity of our existing customers from time to time. This is so we know who our customers are and to make it more difficult for criminals to use false or impersonated identities for criminal purposes, such as hiding the proceeds of crime or committing fraud.

To verify your identity we’ll check the contact details and financial information you provide to us with credit reference agencies and publicly available information.

We’ll also check that you meet the criteria to receive the product or service we’re offering.

We’ll use your information to manage any account, product, service or relationship you have with us, in line with the terms of that arrangement and the rules of our regulators. Examples of this are:

• Administering your account including:
  • authorising payments to and from you;
  • keeping an accurate history of transactions and sending you account statements; and
  • communicating with you about your account and your relationship with us, including notifying you of changes to interest rates, limits or charges.
• Sharing your name and some account details with a person or organisation before a payment can be made to your account.
• Helping to resolve any problems or complaints you may have, or fixing errors.
• Administering any offers or promotions you’ve agreed to participate in.
• Closing your account.

To do this, we’ll use your contact details, the payment details that you have provided to us and your location data to enable us to verify locations at which payments are made for fraud prevention purposes. If you have consented to it, we will also use mobile location services and your IP address to identify you for security and fraud prevention.

We might also share this information with third parties who help us to verify your contact details and deliver our products and services, such as our payment providers, subcontractors and our own service providers for ATMs and cash management, and other banks and regulators.

We may use information to manage any business internet banking money management services provided to business banking customers.

For business customers, our business internet banking money management services use machine learning to provide you with forecasts and projections:

• It is used to provide a simple forecast of revenue for the next three months using the data you have given us access to and other data across the platform (including historical data) such as daily and monthly revenues, industry type, size and location; and
• The forecasting tool provides a prediction of future cash flow position using all of the transactions, invoices and other financial data that cause your bank balance to change. It then looks back at history to find different patterns and trends that it can use to forecast your cashflow. It works directly from your cash movements – rather than your PnL or balance sheet – which means it can consider individual customers and suppliers to make accurate forecasts right down to daily cash movements.

We have a legitimate interest in only lending money to customers who are able to repay it. Our regulators also require us to lend money in a responsible manner. So whenever you apply for credit (e.g. a mortgage, credit card or overdraft) or any increased borrowing on an existing product, we’ll use the information you give us and that we may already hold to assess the risk to us. We’ll also get information from credit reference agencies to undertake credit scoring and/or other risk assessments of your application.

Credit scoring is an efficient way of making fair and responsible decisions about lending money and managing your accounts. It’s an automated process that assesses how you’re likely to run your account, using information from a range of sources to make a decision (see section 4 "Where we collect information from").

We use credit scoring to decide: whether we provide a product or service to you; whether to adjust products or services you have (such as increasing or decreasing credit limits or interest rates(s)); to pre-approve future products or services for you; to authorise overdraft limits; to authorise payments from you; and in some cases where we need to recover a debt from you.

We will notify you where we have used credit assessment. We will also notify you of a change to your credit limit or interest rate based on our credit assessment process, and you'll have the right to ask one of our team to assess it again.

To carry out credit scoring we use:

• information you give to us about your credit history;
• information about those you are financially linked to (such as your partner);
• information we obtain from credit reference agencies (including, but not limited to, those set out in Appendix 1);
• details about how you have used other products and services you have with us or the Group (for example how you are making repayments on other credit products); and
• information we receive about you directly from other third parties, including when you authorise us to access accounts you hold with other banks, as an account information service provider.

See section 7 "Who we share information with", for more about sharing information with credit reference and fraud prevention agencies.

The law requires us to screen applications and to monitor accounts to help combat the threats posed to our society by terrorism and money-laundering and other financial crime. We also have a legitimate interest in avoiding losses caused by financial crime such as fraud. We may also share information with law enforcement agencies and other regulatory bodies or government departments to comply with legal obligations (such as tax and immigration authorities).

We may check and share relevant information held by us (such as your contact details and financial information) with fraud prevention agencies, credit reference agencies, law enforcement and other government agencies and other banks and regulators for the purpose of preventing, detecting and prosecuting financial crime and the funding of terrorism.

To do that, we'll use any information you have given us, that we have obtained from a third party, or that we have obtained by looking at how you use our services, including name, address, date of birth, every country of residence/citizenship, personal identification (which may include passport or driving license number) your IP address, and information about any criminal convictions. This might include information about your location or your device, which helps to detect and prevent crime and fraud.

We have a legitimate interest in recovering debts that are due to us if there isn’t a satisfactory plan in place to repay them.

We'll use your contact details, information we obtain from looking at how you have used our services (including information about your location that we may find from reviewing your accounts), and information available within the Group about how you have used services provided by other members of the Group.

We'll give information to and receive information from third parties where that is necessary to recover debts due by you to us including by bringing legal proceedings in the courts. Examples of third parties include other banks, debt recovery agents, solicitors, credit reference agencies and sheriff officer or bailiff services. This might also include passing information about you to a third party who we have transferred your debt to (for example, for securitisation), and who will then contact you directly to collect that debt. If your debt is transferred to a third party you will be advised of the identity of that third party.

We use your information in this way because it is necessary to perform our contract with you, to exercise our legal rights, and because it is fair and reasonable for us to do so.

We have a legitimate interest in making improvements to how we provide our services and to improve the security and resilience of the computer systems we use. We must also respond to any changes in law or regulation that relates to the protection of the information we hold about you.

We may use the information we hold to help us develop and test our systems (including new technologies and services) to ensure that they are safe and will work in the ways in which we expect them to. When we do this we’ll use processes and technologies that are designed to keep this information secure.

The range of products and services we offer (including those provided by companies outside the Virgin Money UK PLC Group) is constantly evolving.

We have a legitimate interest in telling you about our products, services and any new developments that we think may interest you, but only where we are permitted to do so. For some marketing activity, including telling you about the products and services of other companies, we’ll need to ask for your consent to use your information. We don’t want to send you irrelevant or excessive information, so we’ll use the information we hold, particularly profile information, to decide what to tell you, and how and when we’ll do this. This includes advising business customers who meet a certain scoring threshold that they may be eligible for Sustainability Linked-Loans.

You have a legal right to tell us at any time that you don’t want us to use the information we hold in this way or to withdraw any consent that you have given to us.

We’ll only get in touch in the ways you’ve told us are acceptable to you. If you’ve said you don’t want to see marketing information, you’ll not receive it. You can opt in to, or out of, receiving marketing information at any time by contacting us in the usual way (see section 13 for contact points).

If you are happy to be contacted with marketing, we want you to get the most relevant information about the products and services that will be the most beneficial to you, at the right time. The most effective way for us to do this is to use automated processes to create a profile of you for marketing. To do this, we use:

• information you give to us;
• details about how you have used other products and services you have with us or the Group;
• any feedback you have given us;
• information we have obtained from credit reference agencies (including, but not limited to, those set out in Appendix 1) ; and
• information from other companies we are partnering with (including, but not limited to, those set out in Appendix 3).

We might also receive information about you from a third party and use it to market our products and services to you, where you have given that third party your consent to share the information with us. We may collect your name and address from other service providers for the purpose of providing suitable marketing to you.

Our manual or automated processes analyse this information to decide what products and services to offer to you and to prioritise the marketing messages you receive by; assessing your eligibility for those products and services; assessing how likely they are to be useful for you; and deciding how likely you are to respond. For these purposes we may also gather information about whether you’ve opened or clicked on an email, the type of device you are using and the general area in which you open the email.

The partners we pass your information to for marketing might also carry out marketing profiling using your information for these purposes. See Appendix 3 for a list of our partners and Appendix 4 for the categories of our suppliers. We’ll pass your information to our service providers who help us with these marketing activities.

Sometimes we work with other companies to offer you the best products and services. We’ll sometimes share your information with our partners, and receive information about you from our partners, to make sure that we give you the best, most relevant offers when we market to you (if you have consented). SeeAppendix 3 for a list of our partners and Appendix 4 for the categories of our suppliers.

We have a legitimate interest in organising and running our business in a correct and commercially sensible way and to comply with our legal and regulatory responsibilities to the UK financial system. We may use the financial information we hold (including how you have used our products and services such as your bank accounts and insurance claims) to:

• Analyse how well our Marketing is working.
• Train our team members.
• Analyse trends or behaviours we can see.
• Evaluate performance indicators.
• Assess the profitability (or other indicators) of a particular product, service, sector or element of it when compared to others to inform our future commercial strategy.
• Report to and communicate with our regulators, auditors and governmental agencies.
• Help the preparation and confidential disclosure of information that supports our funding and other activities, e.g. the sale or transfer of our interests in some of our mortgage or credit card accounts or where we may want to re-organise some or all of our businesses through a merger, transfer or sale.

We may pass your information to market research companies and other service providers who assist us with these activities.

Sometimes we will use artificial intelligence to create models to assist in our analysis of trends and behaviours and predict general patterns, for example to evaluate how our marketing is working.

We may also use the information we hold for any other purposes that you have specifically consented to at any time (including over the phone or in our Stores) or, in some limited circumstances, when the law requires or permits us to.

We have a legal obligation to support our vulnerable customers and will use information you give to us or is available from your account transactions which identifies/ indicates a vulnerability (such as a health condition or evidence of financial stress) and information we may receive from another member of our Group which identifies vulnerability, where that is necessary to protect the interests of those customers. We’ll give information to and receive information about a vulnerability from third parties where that is necessary to meet our legal obligations, for example from police, social services or someone acting on your behalf.

We’ll give information to and receive information from third party independent financial advisers and mortgage brokers who have introduced you to us, so that we can provide you with our products and services and manage our relationships with those third parties (including payment of any fees).

To do this, we’ll use information about the general nature of the products and services and information about the value of those products and services.

To provide you with mortgage and certain insurance products, in addition to the information already listed above, we’ll need to use additional information about your needs and circumstances, to ensure that we provide you with the right products and services.

For mortgages this will include details of income and expenditure, assets and liabilities, and details of intended retirement age. For life and critical illness this will include date of birth, smoker status and details of existing policies, and information about how you have used other products and services offered by us or other members of our Group including previous claims under existing policies you have with us as well as with other providers.

We might share all of the information we use for this purpose with third parties who help us to deliver the advice. These third parties include credit checking and fraud prevention agencies and our insurance provider partners. See Appendix 1 for a list of the credit reference and fraud prevention companies we use and Appendix 2 for a list of our insurance provider partners. We use your information in this way because it is in our interests and your interests for you to receive advice about the right products and services for you, and to comply with the rules of our regulators.

• If you apply for a health related insurance product we'll require your information to provide you with services that are suitable for you:
• if we identify that you have a health related vulnerability, we’ll share that within our organisation to the extent needed to protect your interests and provide you with services that are suitable for you;
• if we need to provide you with urgent medical assistance when you are on our premises; and
• to ensure you are treated fairly if financial difficulty arises because of a vulnerability.

Some of our accounts use facial and other biometric recognition technology to enable customers to verify identity when opening accounts – we'll ask for your consent when setting up this access. In addition we also use behavioural biometric recognition technology to verify your identity when you are making online purchases with your debit or credit card. Behavioural Biometrics is the use of machine learning to analyse patterns in activity and to detect whether someone really is who they claim to be when they interact online. This way, we can recognise if the activity is potentially fraudulent.

We may ask for this information to fulfil our regulatory and reporting obligations relating to ensuring fairness and equality in our service delivery.

We may use information about criminal proceedings relating to you to make lending decisions (for example we’ll not lend to you if you have a criminal prosecution pending), for fraud prevention/antimoney laundering purposes and to fulfil our legal and regulatory obligations.

Sometimes the transactions in your bank accounts will reveal special categories information (such as your political opinions, health status, religious beliefs and trade union membership), depending on payments you make and receive. This information may be processed by us to provide account payment services to you and will not be used for any other purpose.

To assess an application for a product or service we’ll perform identity checks on you with one or more credit reference agencies (CRAs). Where you apply for credit we’ll also perform credit checks on you with the CRAs. We may also make periodic checks with CRAs to manage your account with us.

To do this we’ll pass your information to CRAs and they’ll give us information about you. The information we’ll supply includes information from your application and your financial situation and history. CRAs will also supply us with public (including the electoral register) and shared credit, financial situation and financial history information and fraud prevention information.

We’ll continue to exchange information about you with CRAs while you have a relationship with us. We’ll 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. They may supply this information to other organisations.

When CRAs do a credit search they’ll place a footprint on your credit file that may be seen by other lenders and may affect your ability to borrow from them.

If you’re making a joint application, or you tell us that you have a spouse or financial associate, we’ll link your records together - so you should make sure they know what you’re doing, and share this information with them, before applying. CRAs will also link your records together. If you later want to break this link you need to talk directly to the CRAs.

The identities of the CRAs, their role as fraud prevention agencies, the data they hold, the ways in which they use and share information, data retention periods and your data protection rights with the CRAs are explained in more detail in the CRA Information Notice (CRAIN). You can find this on each of the CRA websites at:

• transunion.co.uk/crain Link opens in a new window
• equifax.co.uk/crain Link opens in a new window
• experian.co.uk/crain Link opens in a new window

We may also use services from TransUnion for additional purposes not detailed in the CRA Information Notice (CRAIN) to assist us with fraud prevention, identification and verification as well as other purposes. You can find out how your data will be processed by TransUnion for these additional purposes on the following website: www.transunion.co.uk/legal-information/bureau-privacy-notice.https://www.transunion.co.uk/legal-information/bureau-privacy-notice Link opens in a new window

The CRAs described above also perform roles as fraud prevention agencies (FPAs). In addition we’re a member of CIFAS and National Hunter which are both FPAs.

Before providing a product or service to you we may undertake checks with the FPAs for the purpose of preventing and detecting fraud or money laundering. To do this we’ll supply your information to FPAs and they’ll give us information about you. This will include information from your application or we have received from third parties.

If we or a FPA believes you pose a fraud or money laundering risk, we may refuse to provide a new product or service to you or we may stop providing an existing product or service. We may share any relevant information we receive from a FPA with the CRAs.

A record of any fraud or money laundering risk will be retained by the FPAs, and may result in others refusing to provide services, financing or employment to you.

We and FPAs may also allow law enforcement agencies to access and use your information to detect, investigate and prevent crime. For further information please ask a member of staff or visit:

• www.cifas.org.uk/fpn Link opens in a new window
• www.nhunter.co.uk/privacypolicy Link opens in a new window

The United Kingdom left the European Union on 31 January 2020 and so we will need to transfer your personal information to the UK and to other jurisdictions outside of the European Economic Area so that you can continue to use our products and services. Transfers of your personal data from the EU to the UK will proceed on the basis of an Adequacy Decision by the European Commission in favour of the UK or on the basis of adequate protections which comply with EU GDPR and we will need to continue to comply with EU GDPR in relation to how we process your personal data. In particular, we will continue to keep your data secure. Should you wish to contact us with any questions you have on how we use your information or about your data rights and our obligations as a Data Controller, you can contact our EU representative The Data Warehouse at Keizersgracht 482, 1017EG, Amsterdam, Netherlands or by email at helpdesk@tdwico.com. You can also contact our Data Protection Officer by email at helpdesk@tdwico.com. You can also contact our Data Protection Officer by email at data.protection.officer.queries@virginmoney.com or by post at Group Data Protection Officer, Group Risk, Level 3, 51 West George Street, Glasgow, UK, G2 2JJ.

How long we keep your information for depends on the products and services we deliver to you. We’ll retain information for no longer than is necessary to manage your relationship with us (see section 5 “Why we need the information and what we use it for” and section 6 “Why we need special categories information and what we use it for”) and this will mean that we’ll continue to hold some information for a period of time after your account has closed or our relationship has ended, for example where required by a regulator, for active or potential legal proceedings, to resolve or defend claims, or for making remediation payments.

If you would like any further information about how long we hold your information, please contact our DPO by email at data.protection.officer.queries@virginmoney.com or by post at Group Data Protection Officer, Group Risk, Level 3, 51 West George Street, Glasgow G2 2JJ.

We have told you about the ways in which we use the information we hold.

You can object to our processing of your information. When you make an objection we’ll have up to one month to respond to you. We’ll stop using the information in this way unless we disagree that we should because of a compelling legal justification for continuing to use it. We’ll always tell you what the justification is.

Remember, you can always simply opt out of receiving marketing communications at any time. You can do this by contacting us in the usual way.

You always have the right to ask whether or not we hold information about you. And if we do, what the information is, why we’re holding it, the ways it’s being used, who we share it with, how long we keep it for and whether it has been used for any automated decision making. You’re also entitled to a copy of the information. You can make a request for access free of charge either by email, letter, in person, online or over the phone.

We always want the information we hold to be up to date and accurate. If any of the information we hold is either incorrect or out of date then please tell us and we’ll fix it.

You have the right to ask us to erase or delete information where you consider there is no longer any justification for us holding it, either because:

• The information is no longer needed for the reason we collected it (see section 5 "Why we need the information and what we use it for" and section 6 "Why we need special categories information and what we use it for").
• We held and used the information based only on your consent, which you have now withdrawn.
• You have previously objected to a way in which we use information.
• We have been using the information unlawfully.
• There is a legal obligation on us to erase the information.

When you make a request for information to be erased we’ll have up to one month to respond. If we reject your request we’ll tell you and set out the reasons why we’ll not erase or delete the information.

You have the right to get some of your information that you provided from us in a machine readable format.

In certain circumstances you have a right to block or limit the use of information by us. This may arise where:

• You have challenged the accuracy of the information we hold and we are verifying this.
• You have objected to a use of information (see above) and we are considering whether your objection is valid.
• We have been using your information unlawfully but you want us to continue to hold the information rather than erase it (See “Erasure of Information” above).
• We no longer need to keep the information but you have asked us to hold it because of legal claims you’re involved in.

If for whatever reason you are unhappy with any way we are using your information you should contact us in the first instance so that we can understand your issue and try and resolve it. Please contact us by visiting your local branch or by contacting us via the details on our websites on cbonline.co.uk/contact-us Link opens in a new window for Clydesdale Bank customers, ybonline.co.uk/contact-us Link opens in a new window for Yorkshire Bank customers, youandb.co.uk/help Link opens in a new window for B customers or uk.virginmoney.com/contact/ for Virgin Money customers.

We may ask our DPO to look at your situation.

If we can’t resolve the issue you have the right to complain to the Information Commissioners Office (ICO). The ICO is the UK’s independent body set up to uphold information rights. For further information and contact details https://ico.org.uk Link opens in a new window.

List of our Credit Reference, Credit Rating, Debt Recovery and Fraud Prevention agencies.

List of insurance companies who provide insurance products for our customers.

List of our third party partners.

List of the categories of our suppliers.