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Privacy Principles

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Who is St. James's Place Bank?

St. James's Place Bank is a division of Bank of Scotland plc. In September 2001 the Halifax and the Bank of Scotland merged to form a new banking group called HBOS.

What is the HBOS Group?

For many years, Halifax and Bank of Scotland have been two of the UK's best known and most liked banks. Halifax is the UK's No. 1 mortgage lender and savings provider with 150 years' experience in helping people save for and buy their own homes. And, with over 300 years' experience, Bank of Scotland has developed a leading position in personal and business banking.

The Data Protection Act

The Data Protection Act puts obligations on users of personal information and lays down principles for its use. One principle states that information has to be processed fairly and lawfully. This means that you are entitled to know how we intend to use any information you provide. You can then decide whether you want us to have that information.

To provide outstanding customer service we need accurate client information. You can help by informing us whenever your circumstances change.

Organisations must lodge a notification with the Information Commissioner, describing the purposes for which they process personal information. The details are publicly available from the Commissioner's office at:

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Tel: 01625 545 745
Fax: 01625 524 510

Alternatively, see the Commissioner's website at www.informationcommissioner.gov.uk

What are Cookies?

A 'cookie' is a small piece of information which a website places into your browser and can retrieve later. It cannot be read by any website other than that which placed the cookie. We use cookies for several reasons. For example, we can store your preferences for certain kinds of information, or keep track of your progress through our site. St. James's Place Bank uses Microsoft Active Service Pages which need cookies to operate properly. It is important that your browser is set to accept cookies, otherwise you will only be able to access our marketing site.

How to set your browser to accept or disable cookies

The way in which you can set your browser to accept or disable cookies varies slightly according to exactly what browser (and operating system) you are currently using. Below are full instructions for changing your browser settings to accept or disable cookies

MS Internet Explorer 4 & 5 on Windows

  • From the menu bar select Tools (View in IE4), and then Internet Options.
  • On the Security tab, select Internet Zone at the top.
  • Click Custom Level at the bottom of the dialog box.
  • From the list that appears you can choose Enable or Disable Cookies.
  • Click OK.

MS Internet Explorer 6 on Windows

  • From the menu bar select Tools, and then Internet Options.
  • On the Privacy tab, move the slider up for a higher level of privacy or down for a lower level of privacy.
  • Click OK.

Netscape Navigator 4 on Windows

  • From the menu bar select Edit, and then Preferences.
  • In the list on the left select Advanced.
  • In the cookies section at the lower right you can choose to Accept or Disable all cookies.
  • Click OK.

How we use your personal information

Our main use of your personal information is to look after your account or to provide a specific service you require. Some details we obtain elsewhere - from credit reference to agencies or your employer for instance.

If you apply to us for insurance we will pass your details to the insurer. If you make a claim, any information you give to us or to the insurer may be put on a register of claims and shared with other insurers to prevent fraudulent claims. A list of the participants is available from the insurer.

We may use your account details, transactions and any information provided to us by third parties in our client contact programme.

Occasionally, we may contact you by letter, telephone, email or otherwise to inform you about other products and services which may interest you. We try to limit our client contact programme to acceptable levels, but if you wish to exercise your right to opt out, simply call us on 0845 602 6200 or write to our Head of Regulatory Risk at the following address: St. James's Place Bank, 1 Baird Road, Kirkton Campus, Livingston, West Lothian, EH54 7AZ.

Remember that by opting out of receiving marketing information you will not be told of any offers or new products and services which may benefit you. For example, you may not hear about a new savings or mortgage product that offers you a better rate or saves you money.

Unless you have given us your consent, we will not provide information about you to companies outside our group to use for their own marketing purposes. Sometimes we need to give information to our agents and subcontractors so that they can provide a particular service for us. Sometimes, these companies may be located abroad in countries that do not have data protection laws. In these circumstances we always take great care to ensure that your personal information is kept safe and secure. Your information may also be shared by other members of our group to keep their records up to date and administer your relationship with them.

We are also committed to meeting the standards set by the Banking Code, copies of which are available on request, Occasionally, the Banking Code Standards Board who monitor compliance with the Banking Code, audit a sample of our customer records to assess our compliance with the Code. Whenever this happens, strict confidentiality conditions are always imposed.

Under the Data Protection Act you have the right to have access to information we hold about you on our records. The Act allows us to charge a fee of £10 for this service. If anything is inaccurate or incorrect, please let us know and we will correct it.

If you do not want to receive unsolicited mail from other companies, you can prevent this by registering with the Mailing Preference Service. In addition the Telephone and Fax Preference Services enable you to object to receiving unsolicited marketing phone calls or faxes from other companies. To register, simply telephone the appropriate number below:

Mailing Preference Service: 0207 291 3310
Telephone Preference Service: 0207 291 3320
Fax Preference Service: 0207 291 3330

For more details about all the preference services, please see the Direct Marketing Association's website at: www.dma.org.uk

Credit Referencing

If you apply for a St. James's Place Bank credit based product we will perform a search with a credit reference agency. The agency will keep a record of the search. After you open a credit based product, we will provide the agency with regular information about how you use it. Other lenders may use this to make decisions on future applications for credit. It may also be used for tracing debtors and to prevent fraud.

When opening accounts, we may search public records such as the Electoral Roll that are available from credit reference agencies to help us verify your identity. Occasionally, we search credit and fraud prevention agency files as well as our own internal group records to manage your account and take credit decisions such as whether to offer credit or continue to extend existing credit. These searches are not seen or used by lenders to assess your ability to obtain credit.

'Associations' linking your financial records may be created on credit reference agency records when you apply for facilities or accounts in joint names. Your financial records, and those of anyone financially associated with you, may be considered in any future applications you make.

You have the right to apply to the credit reference agencies for a copy of your credit file. Our credit scoring leaflet contains the relevant forms to help you apply. Please ask us for a copy. If there is anything incorrect on your credit file, you have the right to ask the agency to add a Notice of Correction.

We use Equifax plc, whilst other members of the HBOS Group also use Experian Limited. A third credit reference agency (Call Credit) is also based in the UK. Their addresses are as follows:

Equifax plc, Credit File Advice Centre, PO Box 1140, Bradford BD1 5US (www.equifax.co.uk)
Tel 0870 010 0583

Experian Ltd, Consumer Help Service, PO Box 8000, Nottingham NG1 5GX (www.experian.co.uk)
Tel 0870 241 6212

Callcredit plc, Consumer Services Team, PO Box 491, Leeds West Yorkshire LS3 1WZ(www.callcredit.plc.uk) Tel 0870 060 1414

If you have been refused credit you can get advice from your local Trading Standards Department, Citizens Advice Bureau or Consumer Advice Centre and the agencies' websites. The Information Commissioner also produces a useful leaflet entitled 'Credit Explained'. You can obtain a free copy on the Information Commissioner's website www.informationcommissioner.gov.uk or by telephoning 0870 442 1211.

Credit Scoring

When you apply to us for a credit-based product, the details you provide, the information we already have and information from credit reference agencies are used to assess credit risk using a technique called 'credit scoring'. Various factors in all these details help us to assess the risk. A score is given to each factor and a total credit score obtained. If your score is above a confidential, pre-set pass score, the application is likely to succeed. For more details please ask for a copy of our 'Credit Scoring' leaflet.

Crime prevention and detection

Our systems protect customers and ourselves against fraud and other crime. Customer information can be used to prevent crime and trace those responsible. We may check your details with fraud prevention agencies.

  • If false or inaccurate information is provided and fraud is identified, details will be passed to fraud prevention agencies.
  • Law enforcement agencies may access and use this information.
  • We and other organisations may also access and use this information to prevent fraud and money laundering, for example, when:

  • • Checking details on applications for credit and credit related or other   facilities
    • Managing credit and credit related accounts or facilities
    • Recovering debt
    • Checking details on proposals and claims for all types of insurance
    • Checking details of job applicants and employees
  • Please contact us on 0845 602 6200 if you want to receive details of the relevant fraud prevention agencies.

We and other organisations may access and use from other countries the information recorded by fraud prevention agencies.

Introducers

Your relationship with us was 'introduced' by a third party. We will provide them with sufficient information about you to help with their accounting and administration. The introducer may, with your consent, use your details to contact you about products and services, unless you have asked them not to do so.

Anti-Money Laundering and statutory obligations

To comply with money laundering regulations, and to help stop criminals using financial products or services to launder money, there are times when we need to confirm (or reconfirm) the name and address of our customers. We may need to do this whether you are applying to be a new customer, or have been one for some time. This information may be shared with other HBOS Group companies.

Some Acts of Parliament oblige us to disclose information about our clients to certain bodies with statutory powers. For example, we must give information to authorised benefit fraud investigators where fraudulent benefit claims are suspected. In addition, the Inland Revenue has the statutory authority to audit our clients' accounts from time to time.

Email

If you email us, or give us your email address, we will keep a record of it. We may use it to contact you occasionally about our products and services which may interest you - unless you ask us not to do so. We will not give your email address to any unauthorised third parties. When emailing us, always use the email facility on our website to make sure that the content of your email is secure. If you send us email in other ways, remember that it will be 'insecure' and could be intercepted. If you do send us an 'insecure' email, please keep any confidential information in it to a minimum. We will do the same when we reply.

Telephone calls

We may record telephone conversations to offer you additional security, resolve complaints and improve our service standards. Conversations may also be monitored for staff training purposes.

Responsibility for client confidentiality

All our employees are personally responsible for maintaining client confidentiality. We provide training and education to all our staff to remind them about their obligations. Our policies and procedures are regularly audited and reviewed.

Sensitive Information

The Data Protection Act defines certain information about the following as 'sensitive' (racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, sexual life, criminal proceedings and offences).

If you apply to us for insurance, health insurance or life assurance, we may ask you for some 'sensitive' details. We will only use this information to provide the service you require and we will ask for your explicit consent. Some transactions that you (or an additional cardholder) make on a card account may cause sensitive or confidential details to appear on your statement. If your card is used for such transactions, we believe that the details appear on your statement with your explicit consent.

Business Customers

The Data Protection Act does not generally apply to companies but it does cover sole traders. When we receive an application from such a business we may perform a search with a credit reference agency on the individual company directors or partners.

Links to other websites

The St. James's Place Bank website contains links to sites operated by persons outside the HBOS Group. We are not responsible for the privacy practices, content, or the product and services provided through those sites.

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