This Privacy Notice explains how we hold and use your information within the Virgin Money UK PLC Group 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 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.email@example.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.
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. The companies within our Group are:
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:
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.
We collect information directly from you and others.
We obtain information:
We also get information from:
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. Please see section 5 “Why we need the information and what we use it for” for further information.
Data Protection law requires us to have one or more of the following reasons for using your information:
These are the main ways we’ll use your information (and the reasons for doing so):
(Contract performance; Legal obligation)
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.
(Contract performance; Legal obligation; Legitimate Interests)
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:
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:
(Contract performance; Legal obligation; Legitimate interest)
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:
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.
(Contract performance; Legitimate interest)
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.
(Legal obligation; Legitimate interest)
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.
(Legitimate interest; Consent)
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:
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). See Appendix 3 for a list of our partners and Appendix 4 for the categories of our suppliers.
(Legal obligation; Legitimate interest)
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:
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.
(Legal obligation; Legitimate interest; Consent)
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.
(Contract performance; Legal obligation; Legitimate interest)
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.
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:
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.
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/anti-money 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.
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:
We may also share information we hold with the following types of organisation:
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, financialsituation and financialhistory 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
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:
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 www.ico.org.uk 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.
The United Kingdom left the European Union on 31st 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 firstname.lastname@example.org. You can also contact our Data Protection officer by email at Data.email@example.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.firstname.lastname@example.org or by post at Group Data Protection Officer, Group Risk, Level 3, 51 West George Street, Glasgow G2 2JJ.
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, calling us directly, via online banking or through the Virgin Money App. For contact details, use the Virgin Money App or visit our websites on cbonline.co.uk/contact-us for Clydesdale Bank customers, ybonline.co.uk/contact-us for Yorkshire Bank customers, youandb.co.uk/help for B customers and uk.virginmoney.com/virgin/contact for Virgin Money customers.
You can also update your contact preferences through the Virgin Money App, by visiting a branch or calling us directly. For contact details, visit our websites on cbonline.co.uk/contact-us for Clydesdale Bank customers, ybonline.co.uk/contact-us for Yorkshire Bank customers, youandb.co.uk/help for B customers and uk.virginmoney.com/virgin/contact for Virgin Money customers.
The law guarantees you rights in relation to your information. We have set out details of your rights below under individual headings.
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 justifcation for continuing to use it. We’ll always tell you what the justifcation 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:
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:
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 for Clydesdale Bank customers, ybonline.co.uk/contact-us for Yorkshire Bank customers, youandb.co.uk/help for B customers or uk.virginmoney.com/virgin/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 visit www.ico.org.uk.
You can contact us at any time to discuss how to exercise your data protection rights by emailing us at DSARCCA.Queries@cybg.com. To discuss how we hold and use your information, please contact us by email at Data.email@example.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.
|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|
|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|
List of insurance companies who provide insurance products for our customers.
|Aviva Insurance Limited|
|Aviva Life & Pensions UK Limited|
|AIG Europe Limited|
|Lifestyle Services Group Limited|
|U K Insurance Limited|
|Hiscox Insurance Company Limited|
|Legal and General Assurance Society Limited|
|Royal & Sun Alliance Insurance PLC|
List of our third party partners.
|List of our third party partners|
|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|
|Origen Financial Services Limited|
|AIG Europe Limited|
|Lifestyle Services Group Limited|
|U K Insurance Limited|
|Sodexo Motivation Solutions UK Limited|
|Accelerated Payment Limited|
|Bright HR Limited|
|UT Tax Limited|
List of the categories of our suppliers.
|List of the categories of our suppliers|
|Complaints Management Services|
|Account monitoring and operation|
|Debt Management Services|
|Fraud Monitoring and Services|
|Marketing Campaigns and Services|
|Payment Systems and Services|
|Regulatory Monitoring and Services|
|Sales Monitoring and Services|
|Travel and Events Services|
|Credit Reference Agencies|
|Information Security Services|
|Physical Security Services|
|IT Service Companies|
|Business Management App Services Accounting|
|Accounting Software Services|