Privacy Policy

Bank of Ceylon (UK) Limited (BOCUK)

1. Who are we?

BOCUK is registered in England and Wales: Company number 06736473

BOCUK is a controller for the processing activities specified in this privacy notice that relate to your personal data.

BOCUK have appointed a data protection officer (DPO), who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy notice, would like more information about how we use your personal data, or to exercise any of your data subject rights (see “Your rights”) please contact our DPO using the details set out below:

Write to
Data Protection Officer,
Bank of Ceylon (UK) Limited
1 Devonshire Square, London
EC2M 4WD

Email
info@bankofceylon.co.uk

If you are unhappy with our management of your information, you have the right to lodge a complaint with the Information Commissioner’s Office. Please visit http://www.ico.org.uk/ for more information.

2. Purpose of this privacy policy

This privacy policy aims to give you information on how BOCUK collects and processes your personal data through your use of our website and app and your use of our services, including any data you may provide through the website and app when you provide your details for us to contact you, sign up to our newsletter or apply for any of our products or services.

This website is not intended for children as we will not be offering our services to anyone under 18 years of age.

3. What Personal Data Do We Collect About You?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, tax information and gender.
• Contact Data includes residential address, email address and telephone numbers.
• Financial Data includes bank account information and transactional information from your use of our services.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website and app.
• Profile Data includes your username and password, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our website, products, and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We will not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) nor will we collect any information about criminal convictions and offences without your consent, unless the law requires us to.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms and conditions of our products and services, and you fail to provide that data when requested, we may not be able to provide our products and services to you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. 

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, through our website, or otherwise. This includes personal data you provide when you:

• apply for and use our products or services.
• create an account on our website or app.
• request support from our customer services team.
• subscribe to our service or publications.
• request we contact you or for marketing to be sent to you.
• enter a competition, promotion, or survey; or
• give us feedback or contact us.

Automated technologies or interactions.

As you interact with our website and app, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookies policy for further details.

Third parties or publicly available sources. 

We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from analytics and search information providers such as Google, which may be based outside the UK or the EU.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

Identity and Contact Data from data brokers; or

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.

5. How will we use your personal data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to provide our products and services to you i.e. to perform the contract we are about to or have entered with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. 

6. For what purpose do we use your personal data?

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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

Please note that we will contact you during your relationship with us via email, fax, or phone using the details provided by you. Please ensure that your details held by us are accurate and up to date. Please ensure that your details held by us are accurate and up to date. If you need to update your details, please contact our DPO on 0207 377 1888 or email info@bankofceylon.co.uk.

Tax

If we believe that you have tax obligations in another country, we may disclose personal information of yours with those tax authorities, or with HM Revenue and Customs, who may share the information with other tax authorities.

Credit reference agencies and fraud prevention agencies

We may search, use, and share records held by domestic and international credit reference agencies and fraud prevention agencies, as well as our own internal records to:

• Confirm your identity and prevent fraud or money-laundering.
• Check your credit history and income details for affordability.
• Check details on applications for credit and credit related to other facilities.

Credit reference agencies may check your details against any particulars on any database (public or otherwise) to which they have access to verify your identity.

Credit reference agencies keep a record of all searches, including those used to confirm your identity. Credit reference agencies also keep a record of whether your application is successful and whether you’ve missed any payments. Missing payments can negatively impact your credit rating, so it is best to discuss this with us first before you make an application.

We will inform the credit reference agency if you miss or are late on any payments. The agency may then make your personal information available to other organisations so that they can decide about you or the account holder.

7. Change in purpose?

We will only use your personal data for the purpose(s) for which we collect it, unless we consider that we need to use it for another reason, and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our DPO on info@bankofceylon.co.uk. Where permitted by law we can process your personal data without your knowledge or consent. If we do need to use your personal data for an unrelated purpose, and where the law permits, we will notify you to explain the legal basis which allows us to do so.

8. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above. If you want more detail, you can contact us.  

• Third parties acting on our behalf, including our service providers and agents who help us manage our products and services.
• Credit referencing agencies to check your credit rating.
• Relevant government bodies, authorities, and regulatory bodies to comply with our regulatory and reporting obligations.
• IT providers/hosted IT solution providers to enable us to provide our products and services to you.
• Debt collection agencies in the event we need to collect arrears from you or your company.
• Other financial service companies to help prevent, detect, and prosecute unlawful acts and fraudulent behaviour.
• Our professional advisors (lawyers, accountants, and consultants).
• Any other parties connected with your account e.g. guarantors, joint account holders, fellow company directors.
• Market research companies to assist us in improving our products and service delivery.
• Anyone else where we have your consent, you ask us to share it or where it is required by law.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Sharing where we are obliged under a legal obligation.

We will disclose your personal data to comply with any legal regulations or good governance obligations, or to enforce or to protect our rights, property, or safety, or that of our customers or other persons with whom we have a business relationship. This includes exchanging information (which may include information relating to debts which are owed to you, and the related debtors) with other companies and organisations for the purposes of fraud protection, credit insurance and credit risk reduction.

Sharing information with Fraud Prevention Agencies (FPAs)

Before we provide services, goods, or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

9. What we process and share

The personal data you have provided, we have collected from you, or we have received from third parties may include your:

• name
• date of birth
• residential address and address history
• contact details such as email address and telephone numbers.
• financial information
• employment details
• identifiers assigned to your computer or other internet connected device including your Internet Protocol (IP) address.
• vehicle details

When we and Fraud Prevention Agencies process your personal data, we do so on the basis that we have a legitimate interest in preventing fraud and money laundering, and to verify identity, to protect our business and to comply with laws that apply to us. Such processing is also a contractual requirement of the services or financing you have requested.

We, and Fraud Prevention Agencies, may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

Fraud Prevention Agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

10. Transferring data aboard

We will only send your data outside of the European Economic Area (EEA) to:

• Follow your instructions.
• Comply with a legal or regulatory duty.
• Information we may need to share with our parent company First Rand for legal, regulatory, or financial management purposes.

Should we need to transfer your data outside of the EEA for any reason, we will ensure that there is safeguard in place. Safeguards include contractual obligations imposed on the recipients of your personal data. Those obligations require the recipient to protect your personal data to the standard required in the EEA. For further information, please visit the European Commission Justice web page: (https://commission.europa.eu/law/law-topic/data-protection_en)

Safeguards also include requiring the recipient to subscribe to ‘international frameworks’ intended to enable secure data sharing and where the framework is the means of protection for the personal data.

Fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place. Please note National Hunter rules currently do not allow for processing National Hunter data outside of the UK and European Economic area.

11. What should you do if your personal data changes

You should tell us without delay so that we can update our records. If you were introduced to us by a broker or other intermediary who is Data Controller in its own right, you should contact them separately. In some cases where you exercise rights against us under data protection laws (see below) we may need to inform the broker or other intermediary, but this will not always be the case.

12. How long do we keep your Information

Your data is important to us, and we take all reasonable steps to maintain it safely and securely and fully in accordance with the UK Data Protection Act 2018.

We will keep your personal data for up to six years from end of last financial year of our business relationship with you. This includes credit agreements, applications forms (paper and electronic), ID provided, credit scores, payments default records and complaints.

After this time, the data is securely disposed of.

Fraud Prevention Agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years.

13. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business “need to know”. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

14. Your legal rights in relation to your personal data

The Data Protection Act 2018 and the UK General Data Protection Regulation, UK GDPR, provides a several rights for individuals over their personal data. These being:

Right to be informed – This places an obligation on us as a data controller to tell you how we obtain your personal data and describe how we will use, retain, store, and who we share it with. We have written this privacy policy to explain how we will process your personal data and advise you what your rights are under data protection law.

Right of access – This is commonly known as subject access and is the right which allows you access to your personal data and to supplementary information. This right is subject to certain restrictions.

Right to rectification – You have the right to have your personal data rectified if it is inaccurate or incomplete.

Right to erasure – The right to erasure is also known as “the right to be forgotten”. This right enables you to request the deletion or removal of personal data where there is no compelling reason for its continued processing.

Right to restrict processing – You have the right to request your personal data be “blocked” or suppressed. When processing is restricted, organisations are permitted to store personal data but not to further process it.

Right to data portability – This allows you to obtain and reuse your personal data for your own purposes across different services.

Right to object – You have the right to object to the processing of your personal data under certain circumstances, these being:

• The processing of your personal data for direct marketing purposes, including the profiling of data for direct marketing purposes. This is an absolute right, and processing must cease on the receipt of an objection.
• The processing of your personal data based on legitimate interests (or those of a third party) or a performance of a task in the public interest. The right to object when personal data is processed under this legal basis is not absolute. You must provide us with specific reasons why you object. We will consider your request and decide if our legitimate grounds for processing override your interests, rights, and freedoms. Any decision made will be explained to you in writing.

Rights relating to fully automated decision making – Fully automated individual decision making, is a decision made by automated means without any human involvement.

Individuals have the right not to be subject to automated decision making if to do so would impact on their rights or freedoms unless it is based on one of the following criteria:

• Necessary for the entry into or the performance of a contract; or
• Authorised by domestic law applicable to the controller; or 
• Based on the individual’s explicit consent.

In all cases you have the right to request a human review of any fully automated decision.

You can find more information about your rights at the Information Commissioner’s website: https://ico.org.uk/

15. Changes to the privacy policy and your duty to inform us of changes

We may update our privacy policy from time to time; the updated privacy policy will be published on our website. It is important that you visit our website regularly to stay informed as to how we process your personal data and to understand your information rights under the Data Protection Act 2018 and the UK General Data Protection Regulation, UK GDPR.

It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

16. Information commissioner

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk or call them on 0303 123 1113). However, we would appreciate the opportunity to deal with your concerns before you approach the ICO. Please contact our DPO (Data Protection Officer) on info@bankofceylon.co.uk in the first instance.