Privacy Policy

Last updated on 25.05.2018

This policy explains how Bank of Baroda (referred to in this policy as Bank of Baroda, Bank, we or us) collects and uses information about you in the course of providing services to you. This includes when you use our website or our online services when you apply to become a customer and when we provide services to you as a customer.

We take our data protection obligations seriously and it is important to us that you understand how we use your personal data. This Privacy Policy sets out in detail the purposes for which we process your personal data, who we share it with, what rights you have in relation to that data and everything else that we think it is important for you to know.

This policy covers the following:

  1. What is Personal Information?
  2. Whose Personal Information do we collect?
  3. How do we collect your Personal Information?
  4. What Information do we collect?
  5. How do we use your personal information and what is our legal basis for doing so?
  6. What happens if you do not provide the information which we request?
  7. How do we share your personal information?
  8. When do we transfer your data overseas?
  9. For how long do we keep your personal information?
  10. Your Rights in relation to your information
  11. Right to Object
  12. Exercising your Rights
  13. Complaints

" The table in section 4 of this policy provides an overview of the data that we collect. The table at section 5 of this policy provides an overview of the purposes for which we use that data, and the legal basis which permits us to use your information.

We keep this privacy policy up to date, so if there are any changes to the way in which your personal information is used this privacy policy will be updated and we will notify you of the changes.

Contact details

Our contact details are as follows:

Address: Data Protection Officer, Bank of Baroda,32 City Road, London EC1Y 2BD Telephone: 02074571515

We have appointed a Data Protection Officer. You can contact the Data Protection Officer using the following details:

Email: compliance.uk@bankofbaroda.com

1. What is personal information?

Personal information is any information that tells us something about you or " other third parties". This could include information such as name, contact details, date of birth, medical information and bank account details.

2. Whose personal information do we collect?

We collect information about individual customers if you hold a personal account or a sole trader account. We also collect information about directors, shareholders and guarantors of our corporate customers. In this Privacy Policy we refer to all such individual as you.

3. How do we collect personal information?

We collect personal information about you from various sources including:

4. What information do we collect?

We collect the following categories of information about you:

We collect the following information directly from you: We collect the following information from third parties:
Name Sanctions information, if any
Title PEP information, if any
Date of Birth Mortality information, if any
Contact details such as current and previous address, contact number, email address Bankruptcy/insolvency information, if any
Nationality Information about criminal convictions and offences committed, if any
Citizenship Status Electoral roll information, if any
Employment Status Telephone directory, if any
Income Details Adverse media information
Employer Contact Details Credit history
Marital Status Directorship information in an entity
Dependants Persons of significant control in an entity
Source of Funds and Source of Wealth
Visa Status
ID Document Number (usually passport or driving licence)
Other bank account details
Voice recording (if you call our contact centre or one of our branches)
CCTV footage
Tax residency(ies)
Tax identification number(s)
National Insurance number
Birth details such as town/city/country of birth
Details of public position held if you are a Politically Exposed Person
Details of public positions held by your immediate family, i.e., spouse, partner, children and their spouses and partners, parent if they are Politically Exposed Persons
Details of public positions held by your close associates if they are Politically Exposed Persons
Residential property ownership status
Security information to enable you to access your account and verify your identity
Signatures

5. How do we use your information and what is our legal basis for doing so?

Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so as set out in the data protection legislation. We rely on the following legal bases to use your information for business-related purposes:

There are additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data. We may process criminal conviction information where we need to do so to comply with our regulatory obligations. In the table below we set out an explanation of the purposes for which we use your personal information and the legal bases that permit us to use your personal information for those purpose. Where appropriate, we have also identified our legitimate interests in processing your personal data.

We may process your personal information for more than one legal basis depending on the specific purpose for which we are using your personal data. Please contact us if you need details about the specific legal basis we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose and/or activity Legal basis for processing
To make decisions about providing credit to you or a customer you are connected to
  • Contractual necessity
  • Legitimate interests: carry out checks and use your information to make decisions about lending to a business to which you are connected
To comply with our regulatory duties, including regulatory reporting
  • Legal obligation
To assess customer transactions from a finance, management and regulatory perspective
  • Legitimate interests: assess the nature of transactions being undertaken in order to make improvements to the way that we operate and to manage risks
For business management and planning purposes, including accounting, auditing and compliance with statutory record keeping requirements
  • Legal obligation
  • Legitimate interests: analyse the performance of our business and to assist with financial planning and decisions
For marketing purposes
  • Legitimate interests: promoting our products and services
To deal with legal disputes
  • Legitimate interests: to protect our legal position
For fraud and financial crime prevention
  • Legitimate interests: to protect our business and our customers against fraud and financial crime
To make/receive payments
  • Contractual necessity

6. What happens if you do not provide information that we request?

We need some information so that we can comply with our legal obligations. For example, we need information from you so that we can comply with our regulatory requirements to identify our customers and carry out anti-money laundering checks before we can offer our services to a new customer and during the customer relationship. We also need certain information to enable us to provide our services to you and perform our contract with you. For example, we need your contact information so that we can communicate with you about your account.

Where information is needed for these purposes if you do not provide it we will not be able to provide services to you or the customer you are connected to (as applicable). If you do not provide information as requested during the course of our relationship with you/our customer, we may have to stop providing services to you/our customer (as applicable).

7. How do we share your personal information?

We share your personal information in the following ways:

Credit reporting: "Where you apply for new products, we will share your information with Credit Reference Agencies (CRAs) in order to assess whether you or your business can afford to make the repayments, to manage your account(s) with us, to confirm whether the information you provide is accurate and for fraud and crime prevention purposes.

During the course of your relationship with the Bank we will continue to exchange information about you with CRAs, We will inform the CRAs in respect of your repayment history or if you fail to repay in full or on time. In turn this information may be supplied by CRAs to other organisations.

A CRA search request places a search footprint on your credit file which will be visible when you apply for a loan, credit card, mortgage or attempt to open another account. Where you have made a joint application we will link your records and you should inform the other person of this before submitting the application.

The CRAs have created a joint document called the Credit Reference Agency information Notice which provides further information about how CRAs use your personal data. The notice is available at the following locations:

Where we share your personal information with third parties we ensure that we have appropriate measures in place to safeguard your personal information and to ensure that it is solely used for legitimate purposes in line with this Privacy Policy.

8. When do we transfer your information overseas?

When data is transferred to countries outside of the UK and the European Economic Area those countries may not offer an equivalent level of protection for personal information to the laws in the UK. Where this is the case we will ensure that appropriate safeguards are put in place to protect your personal information.

The countries to which your personal information is transferred and the safeguards in place are detailed below:

India – our parent bank in India provides IT support to us. We have put in place a contract with our parent bank on the model terms approved by the European Commission. For further details, see Commission: Model contracts for the transfer of personal data to third countries.

9. For how long do we keep your information?

As a general rule we keep your personal information for the duration of our contract with you or the customer to which you are connected (as applicable) and for a period of 6 years after that contract ends. However, where we have statutory obligations to keep personal information for a longer period or where we may need your information for a longer period in case of a legal claim, then the retention period may be longer.

10. Your rights in relation to your information

You have a number of rights in relation to your personal information, these include the right to:

11. Right to object

You have a right to object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information

12. Exercising your rights

If you would like to exercise any of your rights or find out more, please contact Data Protection Officer, Bank of Baroda,32 City Road, London EC1Y 2BD.

13. Complaints

If you have any complaints about the way we use your personal information please contact Data Protection Officer, Bank of Baroda,32 City Road, London EC1Y 2BD who will try to resolve the issue. If we cannot resolve your complaint, you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK).

 

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