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 – 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 CYBG.data.protection.officer.queries@cybg.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.
Please note that we have updated our Privacy Notice to reflect the combination of Clydesdale Bank with Virgin Money.
2. About the Virgin Money UK PLC Group
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 Clydesdale Bank PLC. Clydesdale 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.
If you are a customer of Yorkshire Bank Home Loans Limited, when we say ‘we’ or ‘us’ we also mean Yorkshire Bank Home Loans Limited.
When we say 'Group' we mean other members of our group of companies, including holding and subsidiary companies.
View our group of companies:
- Clydesdale Bank PLC
- CYB Intermediaries Limited
- CGF No 9 Limited
- Clydesdale Bank Asset Finance Limited
- Clydesdale Covered Bonds No 2 LLP
- Virgin Money UK PLC
- CYB Investments Limited
- Virgin Money plc
- Virgin Money Unit Trust Managers Ltd
- Virgin Money Personal Financial Service Ltd
- Virgin Money Management Services Ltd
- Virgin Money Holdings (UK) plc
- Yorkshire Bank Home Loans Limited
3. 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.
For some products and services we might need additional information that the law regards as being in a special category because of its sensitivity to you.
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.
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 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 to analyse combined data sets.
- From other people who know you including joint account holders and people you are linked to financially.
- 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’). Please see section 5 "Why we need the information and what we use it for" for further information.
5. Why we need the information and what we use it for
Data Protection law requires us to have one or more of the following reasons for using your information:
- ‘Contract performance’ – the information needed to deliver your account, product or service, e.g. we’ll need to hold your transaction history to give you an account statement.
- ‘Legal obligation’ – we are required by law to process your information, e.g. to verify your identity.
- ‘Legitimate interest’ – we’re allowed to use your information where, on balance, the benefits of us doing so are legitimate and not outweighed by your interests or legal rights e.g. we have an interest in knowing what our customers do and don’t like so we can offer better products and services.
- ‘Consent’ – in some cases we may obtain your consent to use information in a particular way or where the law requires consent to be obtained, e.g. if you consent to us recording something about your health so we can improve the way we communicate with you. Whenever ‘consent' is the only reason for us using the information you have the right to change your mind and change or withdraw your consent. Please see section 12 "Your legal rights in relation to your information" for details about how to withdraw your consent to marketing.
Using your information
These are the main ways we’ll use your information (and the reasons for doing so):
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 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.
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 "Contacting us for further information", 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 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). See Appendix 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.
- 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 which identifies a vulnerability (such as a health condition) 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.
6. Why we need special categories information and what we use it for
Special protection is given to special categories information. We'll only use this kind of information if we have one or more of the following reasons for using your information:
- 'Legal obligation' - where we have a specified legal obligation e.g. to protect vulnerable people.
- 'Vital interests' – where we need to protect your vital interests e.g. if you have a severe and immediate medical need whilst on our premises.
- 'Public interest' – where it is in the substantial public interest.
- 'Prevention or detection of crime' – where it is necessary to prevent or detect crime e.g. to identify fraud
- 'Insurance purposes' – where it is necessary for insurance purposes.
- 'Explicit consent' – where you have given us explicit consent to use the information.
Using special categories information
We use the following special categories information for the purposes set out below. Click each heading to find out more.
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.
We may ask for this information to fulfil our regulatory and reporting obligations relating to ensuring fairness and equality in our service delivery.
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.
7. Who we share information with
When using the information we hold we may share it with other people or organisations.
We’ll treat the information we hold as confidential and may share information with the following who are also required to keep the information confidential, safe and secure:
- The companies within the Virgin Money UK PLC Group.
- Other companies, commercial partners, agents and professionals who provide products, services and administrative support to the Virgin Money UK PLC Group (e.g. our IT Suppliers).
- The companies, organisations and professionals who provide other services to you.
- Anyone we may transfer our rights and duties under any arrangement to.
- Anyone else with your permission, including for open banking (which allows you to ask for data to be shared between financial services providers to give you a wider choice of integrated products and services).
We may also share information we hold with the following types of organisation:
- Credit reference agencies.
- Fraud prevention agencies.
- UK and overseas regulators, authorities and their service providers (e.g. the Financial Conduct Authority or the local agents under the Help to Buy scheme).
- UK and overseas tax authorities (e.g. HM Revenue & Customs).
- UK and overseas law enforcement agencies (e.g. the National Crime Agency).
How we work with credit reference and fraud prevention agencies
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:
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: 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:
8. Using information outside the United Kingdom
We may need to transfer your information outside the UK and the EEA to other Group companies, service providers, agents, subcontractors and regulatory authorities in countries where data protection laws may not provide the same level of protection as those in the UK and the EEA, such as the USA.
For example, if you hold a credit or debit card with us, we’ll share transaction details with the payment network (e.g. MasterCard) who may process this information worldwide. In these cases we’ll take all reasonable steps necessary to make sure your information is protected to UK standards. This may be through only allowing transfers to countries which the EU Commission has decided ensures an adequate level of protection for your information (an "adequacy decision"), or we have put in place our own measures to ensure adequate security as required by data protection law.
These measures include having recognised safeguards in place with our commercial partners, such as carrying out strict security checks on our overseas partners and suppliers, backed by strong contractual undertakings approved by the relevant regulators such as the EU style model clauses or where our commercial partner is a signatory to a recognised and binding code of conduct. You can find out more information about standard contractual clauses as detailed by the ICO. Visit their website at ico.org.uk Link opens in a new window and search for 'International Transfers'.
To find out more about any particular uses of information in countries outside the EEA, the existence of an “adequacy decision” for that country or the safeguards we have put in place, please contact our DPO.
9. How long we hold information
How long we keep your information for depends on the products and services we deliver to you.
10. Keeping you up to date
We'll communicate with you about products and services we are delivering using any contact details you have given us – for example by post, email, text message, social media and notifications on our app or website.
Where you have given us consent to receive marketing, you can withdraw consent, and update your marketing preferences by visiting a branch or calling us directly. For contact details, visit 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 and uk.virginmoney.com/contact/ for Virgin Money customers.
You can also update your contact preferences by visiting a branch or calling us directly. For contact details, visit 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 and uk.virginmoney.com/contact/ for Virgin Money customers.
11. Your online activities
We use cookies to track your use of our website. We may use cookies to provide tailored marketing messages when you are logged into our website, if you have given us consent. For further information on our use of cookies visit:
12. Your legal rights in relation to your information
The law guarantees you rights in relation to your information. We have set out details of your rights below under individual headings. Click on these to find out more.
13. Contacting us for further information
You can contact us at any time to discuss how we hold and use your information and how to exercise your data protection rights. Please contact us by email at CYBG.data.protection.officer.queries@cybg.com or by post at Group Data Protection Officer, Group Risk, Level 3, 51 West George Street, Glasgow G2 2JJ.
List of our Credit Reference, Credit Rating, Debt Recovery and Fraud Prevention agencies.
Supplier | Service |
---|
Equifax Limited | Credit Referencing |
Experian Limited | Credit Referencing |
CreditSafe Business Solutions Limited | Credit Referencing |
TransUnion International UK Limited | Credit Referencing |
Dun & Bradstreet Limited | Credit Referencing |
Eunexus Pty Ltd | Fraud Prevention |
AML Analytics Limited | Fraud Prevention |
BAE Systems Applied Intelligence (UK) Limited | Fraud Prevention |
DIA Europe B.V. | Fraud Prevention |
CA Limited | Fraud Prevention |
Fiserv UK Limited | Fraud Prevention |
CIFAS | Fraud Prevention |
National Hunter Ltd | Fraud Prevention |
Apex Credit Management Limited | Debt Recovery |
Blue Stone Credit Management | Debt Recovery |
Fitch Solutions Limited | Credit Rating |
Moody's Analytics UK Limited | Credit Rating |
Thomson Reuters | Fraud Prevention |
LexisNexis | Fraud Prevention |
Vocalink | Fraud Prevention |
List of insurance companies who provide insurance products for our customers.
Insurance Companies |
---|
Aviva Insurance Limited |
Aviva Life & Pensions UK Limited |
AIG Europe Limited |
Lifestyle Services Group Limited |
U K Insurance Limited |
P&MM Limited |
Hiscox Insurance Company Limited |
Legal and General Assurance Society Limited |
Royal & Sun Alliance Insurance PLC |
List of our third party partners.
Third Party Partners |
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Royal and Sun Alliance Insurance PLC |
Legal and General Assurance Society Limited |
Hiscox Insurance Company Limited |
The Royal London Mutual Insurance Society Limited |
Arthur J. Gallagher Insurance Brokers Limited |
Travelex Currency Services Limited |
Worldpay (UK) Limited |
Origen Financial Services Limited |
Mazars Limited |
AIG Europe Limited |
Lifestyle Services Group Limited |
U K Insurance Limited |
Sodexo Motivation Solutions UK Limited |
List of the categories of our suppliers.
Categories of Suppliers |
---|
Complaints Management Services |
Account monitoring and operation |
Customer Services |
Debt Management Services |
Fraud Monitoring and Services |
Insurance Services |
Legal Services |
Lending decisions |
Marketing Campaigns and Services |
Payment Systems and Services |
Professional Services |
Regulatory Monitoring and Services |
Sales Monitoring and Services |
Travel and Events Services |
Regulatory Reporting |
Credit Reference Agencies |
Information Security Services |
Physical Security Services |
Government Services |
IT Service Companies |