1. Who we are
1.1 This privacy notice (the "Privacy Notice") applies to all personal information processing activities carried on by The Royal Bank of Scotland plc (“RBS”) in relation to Business Banking Switch.
1.2 RBS is a data controller in respect of personal information that we process in connection with our business (including the products and services that we provide). In this notice, references to “we”, “us” or “our” are references to RBS.
1.3 Our principal address is RBS Business Banking, 36 St Andrew Square, Edinburgh, EH2 2YB and our contact details can be located at www.rbs.co.uk.
1.5 We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with the Business Banking Switch Scheme. In relation to our general banking products and/or services we are providing to you, please refer to your Terms and Conditions as well as your main notice. “Personal information” means information about a living individual who can be identified from that information (either by itself or when it is combined with other information). We may update our Privacy Notice from time to time, by communicating such changes to you and publishing the updated Privacy Notice on our website. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.
2. The information we process
2.1 We collect and process various categories of information in relation to Business Banking Switch through this site. We will limit the collection and processing of information to information necessary to achieve one or more legitimate purposes as identified in this notice. Personal information may include:
a) basic personal information, including name, business name, post code and contact details;
b) financial information, including account and transactional information and history;
c) Information about your financial circumstances; and/or
d) online profile and social media information and activity, based on your interaction with us and our websites and applications, including for example, your banking profile and login information, Internet Protocol (IP) address, smart device information, location coordinates, online and mobile banking security authentication, mobile phone network information, searches, site visits and spending patterns.
2.2 We may also process certain special categories of information for specific and limited purposes, such as detecting and preventing financial crime or to make our services accessible to customers. We will only process special categories of information where we’ve obtained your explicit consent or are otherwise lawfully permitted to do so (and then only for the particular purposes and activities set out at Schedule A for which the information is provided). This may include:
a) information about racial or ethnic origin;
b) religious or philosophical beliefs;
c) trade union membership;
d) physical or psychological health details or medical conditions; and
e) biometric information, relating to the physical, physiological or behavioural characteristics of a person, including for example using voice recognition or similar technologies to help us prevent fraud and money laundering.
2.3 Where permitted by law, we may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. It may involve investigating and gathering intelligence on suspected financial crimes, fraud and threats and sharing data between banks and with law enforcement and regulatory bodies.
2.4 For the purpose of Business Banking Switch we collect and process specific information. The information we collect via the Business Banking Switch website is provided to bank/s participating in Business Banking Switch, and constitutes the following:
a) Full name;
b) Email address and;
c) Phone number where provided.
2.5 We create the following customer references that are shared with banks participating in Business Bank Switch to ensure the smooth running of Business Banking Switch:
a) Consent ID (CID);
b) Unique Customer Identifier (UCI);
c) Turnover banding;
d) Offer Reference (OR); and
e) Business name.
2.6 We share the following customer references with Banking Competition Remedies Limited, the independent body set up to oversee and administer Business Banking Switch:
a) CASS switching number; and
b) Unique Customer Identifier (UCI).
3. How we obtain information
3.1 Your information is made up of all the financial and personal information we collect and hold about you/your business and the proprietors, officers and beneficial owners of that business and your transactions. It includes:
a) information you give to us;
b) the information we hold in relation to our general banking products and/or services we are providing to you;
c) information that we receive from third parties (including other RBS group companies, third parties who provide services to you or us, credit reference, fraud prevention or government agencies, and other banks (where permitted by law);
d) information that we learn about you through our relationship with you and the way you operate your accounts and/or services, such as the payments made to and from your accounts; and
e) information that we gather from the technology which you use to access our services (for example location data from your mobile phone, or an IP address or telephone number) and how you use it (for example pattern recognition);
f) As well as the cookies we use on our website we gather information from tracking technologies in emails. These help us to understand whether you’ve opened an email and how you’ve interacted with it. Cookies may also be set if you click on a link within the email.
The types of tracking in email we use are:
- Server log events to track links clicked
- Pixel images to track emails opened
g) Information that we gather from publicly available sources, such as the press, the electoral register, company registers and online search engines.
4. Your rights
4.1 We want to make sure you are aware of your rights in relation to the personal information we process about you. We have described those rights and the circumstances in which they apply in the table below.
4.2 If you wish to exercise any of these rights, or if you have any queries about how we use your personal information which are not answered here, please contact us at www.rbs.co.uk, speak to your relationship manager or call us on 0800 151 2980.
4.3 Please note that in some cases, if you do not agree to the way we process your information, it may not be possible for us to continue to operate your account.
Table A - Your Rights
|Access - You have a right to get access to the personal information we hold about you.||
If you would like a copy of the personal information we hold about you, contact us:
UK: 03457 24 2424
For more information on how to get access to your information and the documents we need you to submit, please visit our website at: https://www.supportcentre-rbs.co.uk/Searchable/1022957922/How-do-I-submit-a-Subject-Access-Request-SAR.htm
|Rectification – You have a right to rectification of inaccurate personal information and to update incomplete personal information.||
If you believe that any of the information that we hold about you is inaccurate, you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal information.
Please note that if you request us to restrict processing your information, we may have to suspend the operation of your account and suspend participation in Business Banking Switch which may include suspension of any switching requests to a participating bank.
|Erasure – You have a right to request that we delete your personal information.||
You may request that we delete your personal information if you believe that:
Please note that if you request us to delete your information, we may have to suspend the operation of your account and/or participation in Business Banking Switch which may include the suspension of any switching request to a participating bank.
|Restriction – You have a right to request us to restrict the processing of your personal information.||
You may request us to restrict processing your personal information if you believe that:
Please note that if you request us to restrict processing your information, we may have to suspend the operation of your account and/or participation in Business Banking Switch which may include the suspension of any switching request to a participating bank.
|Portability – You have a right to data portability.||
Where we have requested your permission to process your personal information or you have provided us with information for the purposes of entering into a contract with us, you have a right to receive the personal information you provided to us in a portable format.
You may also request us to provide it directly to a third party, if technically feasible. We’re not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you.
If you would like to request the personal information you provided to us in a portable format, contact us on
UK: 03457 24 2424
For more information on how to get access to your information and the documents we need you to submit, please visit our website at: https://www.supportcentre-rbs.co.uk/Searchable/1022957922/How-do-I-submit-a-Subject-Access-Request-SAR.htm
|Objection – You have a right to object to the processing of your personal information.||
You have a right to object to us processing your personal information (and to request us to restrict processing) for the purposes described in Schedule A Section C unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests or where we need to process your information to investigate and protect us or others from legal claims.
Depending on the circumstances, we may need to restrict or cease processing your personal information altogether, or, where requested, delete your information. Please note that if you object to us processing your information, we may have to suspend the operation of your account and/or the participation in Business Banking Switch which may include the suspension of any switching request to a participating bank.
|Marketing – You have a right to object to direct marketing||
You have a right to object at any time to processing of your personal information for direct marketing purposes, including profiling you for the purposes of direct marketing. For more information see Section 9.
|Withdraw consent – You have a right to withdraw your consent.||
Where we rely on your permission to process your personal information, you have a right to withdraw your consent at any time. We will always make it clear where we need your permission to undertake specific processing activities.
|Lodge complaints – You have a right to lodge a complaint with the regulator||
If you wish to raise a complaint on how we have handled your personal information, you can contact our Data Protection Officer who will investigate the matter. We hope that we can address any concerns you may have, but you can always contact the Information Commissioner’s Office (ICO). For more information, visit https://ico.org.uk.
5. Changes to the way we use your information
From time to time we may change the way we use your information. Where we believe you may not reasonably expect such a change we will notify you and will allow a period of at least 30 days for you to raise any objections before the change is made. However, please note that in some cases, if you do not agree to such changes it may not be possible for us to continue to operate your account and/or the participation in Business Banking Switch which may include acting on any switching request to a participating bank.
6. How we use and share your information with other RBS group companies
We will only use and share your information where it is necessary for us to lawfully carry out our business activities. Your information may be shared with and processed by other RBS group companies. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail in a table in Schedule A - Purposes of processing.
7. Sharing with third parties
7.1 We will not share your information with anyone outside RBS except:
a) Where we have your permission.
b) Where required for your product, service or administration of Business Banking Switch. This includes sharing with participating banks and/or Banking Competition Remedies Limited. You can find out more about the data we share with participating banks in section 2.4.
If you wish to know more about how your chosen bank/s or Banking Competition Remedies Limited will use your personal data, please refer to their respective privacy notice/s.
c) Where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world;
d) With third parties providing services to us, such as market analysis and benchmarking, correspondent banking, and agents and sub-contractors acting on our behalf, such as the companies which print our Business Banking Switch Scheme correspondence.
e) With other banks to help trace funds where you are a victim of suspected financial crime and you have agreed for us to do so, or where we suspect funds have entered your account as a result of a financial crime.
g) Where required for a proposed sale, reorganisation, transfer, financial arrangement, asset disposal or other transaction relating to our business and/or assets held by our business.
h) In anonymised form as part of statistics or other aggregated data shared with third parties; or
i) where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above.
7.2 Withdrawing your interest
If you have already submitted your interest to the participating bank(s) through Business Banking Switch, you can withdraw your interest on a per-offer basis by removing your consent from them contacting you.
Removing your interest will also remove your consent to be contacted by the banks.
8. Transferring information overseas
8.1 We may transfer your information to organisations in other countries (including to other RBS group companies) on the basis that anyone to whom we pass it protects it in the same way we would and in accordance with applicable laws.
8.2 In the event that we transfer information to countries outside of the European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway), we will only do so where:
a) the European Commission has decided that the country or the organisation we are sharing your information with will protect your information adequately;
b) the transfer has been authorised by the relevant data protection authority; and/or
c) we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the European Commission) to ensure your information is adequately protected. If you wish to obtain a copy of the relevant data protection clauses, please contact us at www.rbs.co.uk, speak to your relationship manager or call us on 0800 151 2980.
9. Business Banking Switch Marketing information
By registering your details on the Business Banking Switch website you are agreeing to be contacted about Business Banking Switch only by mail, phone, email and other forms of electronic communication in line with your chosen contact channel. Your normal marketing preferences for RBS won’t be affected and you’ll not be opted in to wider marketing. If you change your mind about how you would like to be contacted or you no longer wish to receive Business Banking Switch marketing, you can tell us anytime by visiting https://businessbankingswitch.rbs.co.uk/unsubscribe, calling 0800 151 2980 or speaking to your relationship manager.
If you would like to change your general RBS contact preferences please tell us by contacting us at https://www.rbs.co.uk/personal/unsubscribe.ashx, speaking to your relationship manager or calling us on 0800 151 2980.
RBS will not share your information with third parties for their own marketing purposes without your permission.
10. Communications about your account
10.1 We will contact you with information relevant to you about Business Banking Switch (including updated information about how we process your personal information), by a variety of means including via online banking, mobile banking, email, text message, post and/or telephone. If at any point in the future you change your contact details you should tell us promptly about those changes.
10.2 We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes outlined in Schedule A - Purposes of Processing.
11. How long we keep your information
11.1 By providing you with products or services as well as managing Business Banking Switch, we create records that contain your information, such as customer account records, activity records, tax records and lending and credit account records. Records can be held on a variety of media (physical or electronic) and formats.
11.2 We manage our records to help us to serve our customers well (for example for operational reasons, such as dealing with any queries relating to your account) and to comply with legal and regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities.
11.3 Retention periods for records are determined based on the type of record, the nature of the activity, product or service, the country in which the relevant RBS company is located and the applicable local legal or regulatory requirements. We (and other RBS group companies) normally keep customer account records for up to six years after your relationship with the bank ends, whilst other records are retained for shorter periods, for example ninety days for CCTV records or twelve months for call recordings. Retention periods may be changed from time to time based on business or legal and regulatory requirements.
11.4 We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that the bank will be able to produce records as evidence, if they're needed.
11.5 If you would like more information about how long we keep your information, please contact us at www.rbs.co.uk, speak to your relationship manager or call us on 0800 151 2980.
We are committed to ensuring that your information is secure with us and with the third parties who act on our behalf. For more information about the steps we are taking to protect your information please visit:
Schedule A - Schedule of Purposes of Processing
We will only use and share your information where it is necessary for us to carry out our lawful business activities. Your information may be shared with and processed by other RBS group companies. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail in the tables below:
|A. Contractual necessity|
We may process your information where it is necessary to enter into a contract with you for the provision of our products or services or to perform our obligations under that contract. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide products and services to you. This may include processing to:
a) assess and process applications for products or services;
b) provide and administer those products and services throughout your relationship with the bank, including opening, setting up or closing your accounts or products, collecting and issuing all necessary documentation, executing your instructions, processing transactions, including transferring money between accounts, making payments to third parties, resolving any queries or discrepancies and administering any changes. Calls to our service centre and communications to our mobile and online helplines may be recorded and monitored for these purposes;
c) manage and maintain our relationships with you and for ongoing customer service. This may involve sharing your information with other RBS group companies to improve the availability of our services, for example enabling customers to visit branches of other RBS group companies;
d) administer any credit facilities or debts, including agreeing repayment options; and
e) communicate with you about your account(s) or the products and services you receive from us.
|B. Legal obligation|
When you apply for a product or service (and throughout your relationship with us), we are required by law to collect and process certain personal information about you. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide products and services to you. This may include processing to:
f) confirm your identity, including using biometric information and voice-recognition technology and other identification procedures, for example fingerprint verification;
g) perform checks and monitor transactions and location data for the purpose of preventing and detecting crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. This may require us to process information about criminal convictions and offences, to investigate and gather intelligence on suspected financial crimes, fraud and threats and to share data with law enforcement and regulatory bodies;
h) assess affordability and suitability of credit for initial credit applications and throughout the duration of the relationship, including analysing customer credit data for regulatory reporting;
i) share data with other banks and third parties to help recover funds that have entered your account as a result of a misdirected payment by such a third party;
j) share data with police, law enforcement, tax authorities or other government and fraud prevention agencies where we have a legal obligation, including reporting suspicious activity and complying with production and court orders;
k) deliver mandatory communications to customers or communicating updates to product and service terms and conditions.
l) investigate and resolve complaints;
m) conduct investigations into breaches of conduct and corporate policies by our employees;
n) manage contentious regulatory matters, investigations and litigation;
o) perform assessments and analyse customer data for the purposes of managing, improving and fixing data quality;
p) provide assurance that the bank has effective processes to identify, manage, monitor and report the risks it is or might be exposed to;
q) investigate and report on incidents or emergencies on the bank’s properties and premises;
r) coordinate responses to business disrupting incidents and to ensure facilities, systems and people are available to continue providing services.
|C. Legitimate interests of the bank|
We may process your information where it is in our legitimate interests do so as an organisation and without prejudicing your interests or fundamental rights and freedoms.
a) We may process your information in the day to day running of our business, to manage our business and financial affairs and to protect our customers, employees and property. It is in our interests to ensure that our processes and systems operate effectively and that we can continue operating as a business. This may include processing your information to:
(i) monitor, maintain and improve internal business processes, information and data, technology and communications solutions and services;
(ii) ensure business continuity and disaster recovery and responding to information technology and business incidents and emergencies;
(iii) ensure network and information security, including monitoring authorised users’ access to our information technology for the purpose of preventing cyber-attacks, unauthorised use of our telecommunications systems and websites, prevention or detection of crime and protection of your personal data;
(iv) provide assurance on the bank's material risks and reporting to internal management and supervisory authorities on whether the bank is managing them effectively;
(v) perform general, financial and regulatory accounting and reporting;
(vi) protect our legal rights and interests;
(vii) manage and monitor our properties and branches (for example through CCTV) for the purpose of crime prevention and prosecution of offenders, for identifying accidents and incidents and emergency situations and for internal training; and
(viii) enable a sale, reorganisation, transfer or other transaction relating to our business.
(ix) administer the Business Banking Switch scheme and fulfil our associated obligations to Banking Competition Remedies Limited, as well as the participating banks.
b) It is in our interest as a business to ensure that we provide you with the most appropriate products and services and that we continually develop and improve as an organisation. This may require processing your information to enable us to:
(i) identify new business opportunities and to develop enquiries and leads into applications or proposals for new business and to develop our relationship with you;
(ii) send you relevant marketing information (including details about Business Banking Switch).
(iii) understand our customers’ actions, behaviour, preferences, expectations, feedback and financial history in order to improve our products and services, develop new products and services, and to improve the relevance of offers of products and services by RBS group companies;
(iv) monitor the performance and effectiveness of Business Banking Switch;
(v) assess the quality of our customer services and to provide staff training. Calls to our service centres and communications to our mobile and online helplines may be recorded and monitored for these purposes;
(vi) perform analysis on customer complaints for the purposes of preventing errors and process failures and rectifying negative impacts on customers;
(vii) compensate customers for loss, inconvenience or distress as a result of services, process or regulatory failures;
(viii) identify our customers’ use of third party products and services in order to facilitate the uses of customer information detailed above; and
(ix) combine your information with third party data, such as economic data in order to understand customers’ needs better and improve our services.
We may perform data analysis, data matching and profiling to support decision making with regards to the activities mentioned above. It may also involve sharing information with third parties who provide a service to us.
c) It is in our interest as a business to manage our risk and to determine what products and services we can offer and the terms of those products and services. It is also in our interest to protect our business by preventing financial crime. This may include processing your information to:
(i) carry out financial, credit and insurance risk assessments;
(ii) manage and take decisions about your accounts;
(iii) carry out checks (in addition to statutory requirements) on customers and potential customers, business partners and associated persons, including performing adverse media checks, screening against external databases and sanctions lists and establishing connections to politically exposed persons;
(iv) share data with credit reference, fraud prevention agencies and law enforcement agencies;
(v) trace debtors and recovering outstanding debt;
(vi) for risk reporting and risk management.