Our Privacy Notice: How Hodge uses your personal information
This privacy notice is our promise of how we look after your personal information. It includes how we use information that you tell us about yourself, what we learn by having you as a customer, and the choices you give us about what marketing you want us to send you. This notice explains how we do this and tells you about your privacy rights and how the law protects you.
Who are Hodge?
Hodge (noted as “we” in this document) is made up of a number of different legal entities. We’ll let you know which you have a relationship with, when you take out a product or service with us.
If you have any questions, or want more details about how we use your personal information, you can follow the links below to specific areas of our websites:
Here you can also find links on how you can email or call us.
Our Privacy Promise to you
- To keep your data safe and private.
- To not sell your data to any third parties.
- To give you ways to manage and review your marketing choices at any time.
- To not send your data outside of the European Economic Area unless we have your permission.
- To protect any data we hold about children.
- To have extra precautions in place to secure sensitive data we hold about you.
- To notify you of any data breaches as necessary.
A summary of the General Data Protection Regulation
The General Data Protection Regulation (GDPR) 2018 replaces Data Protection Act 1998. Its purpose is to protect the “rights and freedoms” of natural persons (i.e. living individuals) and to ensure that personal data is not processed without their knowledge, and, wherever possible, that it is processed with their consent.
The GDPR applies to the processing of personal data wholly or partly by automated means (i.e. by computer) and to the processing of personal data other than by automated means (i.e. paper records) that form part of a filing system or are intended to form part of a filing system.
The GDPR will apply to all controllers that are established in the EU (European Union) who process the personal data of data subjects, in the context of that establishment. It will also apply to controllers outside of the EU that process personal data in order to offer goods and services, or monitor the behaviour of data subjects who are resident in the EU.
How does the data protection law protect me?
As well as our promise to you that we will protect your data, your privacy is protected by law. This section explains how that works.
Data Protection law says that companies are only allowed to use personal information when they have a lawful basis to do so, for example, where they have your consent which is often undertaken via a contract. Under the GDPR, there are six lawful bases for processing and companies must determine the lawful basis they have before they use/process your data.
- Consent: the individual has given clear consent to process their personal data for a specific purpose.
- Contract: the processing is necessary for a contract.
- Legal obligation: the processing is necessary to comply with the law (not including contractual obligations).
- Vital interests: the processing is necessary to protect someone’s life.
- Public task: the processing is necessary to perform a task in the public interest or official functions, and the task or function has a clear basis in law.
- Legitimate interests: the processing is necessary for legitimate interests or the legitimate interests of a third party.
What basis does Hodge use to process my personal data?
We will only process your personal data when we have a ‘lawful’ basis to do so:
- To fulfil a contract we have with you, or because you have asked us to process your personal data to support entering into a contract.
- When it is our legal duty to do so, for example where we are required to comply with money laundering regulations.
- When it is in our and your legitimate interest, for example, tailoring our service to meet your specific needs. Where you have expressly provided consent to undertake a specific activity.
- Where we perform a task in the public interest, for example sharing fraudulent information with relevant bodies.
- Where the legitimate interest has a sound business reason and we are processing your information in a way that is ‘best for you’.
How does Hodge collect and use my personal information?
Here is a list of all the ways that we may use your personal information, and which of the reasons we rely on to do so. This is also where we tell you what our legitimate interests are.
|What we use your personal information for||Our Reasons||Our Legitimate Interests|
|To manage our relationship with you or your business.||
||Keeping our records up to date, working out which of our products and services may interest you and telling you about them.|
|To develop new ways to meet our customers’ needs and to grow our business.||Developing products and services, and what we charge for them.|
|To develop and carry out marketing activities.||Defining types of customers for new products or services.|
|To study how our customers use products and services from us and other organisations.||Seeking your consent when we need it to contact you.|
|To provide advice or guidance about our products and services.||Being efficient about how we fulfil our legal duties.|
|To develop and manage our brands, products and services.||
||Developing products and services, and what we charge for them.|
|To test new products.||Defining types of customers for new products or services.|
|To manage how we work with other companies that provide services to us and our customers.||Being efficient about how we fulfil our legal and contractual duties.|
|To deliver our products and services.||
||Being efficient about how we fulfil our legal and contractual duties.|
|To make and manage customer payments.||Complying with regulations that apply to us.|
|To manage fees, charges and interest due on customer accounts.|
|To collect and recover money that is owed to us.|
|To manage and provide treasury and investment products and services.|
|To detect, investigate, report, and seek to prevent financial crime.||
||Developing and improving how we deal with financial crime, as well as doing our legal duties in this respect.|
|To manage risk for us and our customers.||Complying with regulations that apply to us.|
|To obey laws and regulations that apply to us.||Being efficient about how we fulfil our legal and contractual duties.|
|To respond to complaints and seek to resolve them.||
|To run our business in an efficient and proper way. This includes managing our financial position, business capability, planning, communications, corporate governance, and audit.||
||Complying with regulations that apply to us.|
|Being efficient about how we fulfil our legal and contractual duties.|
|To exercise our rights set out in agreements or contracts.|
What does personal data mean and what types of personal information are included?
‘Personal data’ means any information that enables a person to be directly and/or indirectly identified in both electronic and physical formats.
In order to carry out our work with you, we collect many types of personal information as listed:
|Type of personal information||Description|
|Financial||Your financial position, status and history.|
|Contact||Where you live and how to contact you.|
|Socio-Demographic||This includes details about your work or profession, nationality, education and where you fit into general social or income groupings.|
|Transactional||Details about payments to and from your accounts with us.|
|Contractual||Details about the products or services we provide to you.|
|Behavioural||Details about how you use our products and services.|
|Technical||Details on the devices and technology you use.|
|Communications||What we learn about you from letters, emails and conversations between us.|
|Open Data and Public Records||Details about you that are in public records, such as the Electoral Register, and information about you that is openly available on the internet.|
|Documentary Data||Details about you that are stored in documents in different formats, or copies of them. This could include things like your passport, drivers licence or birth certificate.|
|Special types of data||The law and other regulations treat some types of personal information as special. We will only collect and use these types of data if the law allows us to do so:
|Consents||Any permissions, consents or preferences that you give us, such as marketing you opt-in to.|
|National Identifier||A number or code given to you by a government to identify who you are, such as a National Insurance number.|
Where does Hodge get my personal information from?
There are a number of places where we obtain your personal information:
Data you give to us:
- When you apply for our products and services
- When you talk to us on the phone
- When you use our websites
- In emails and letters
- In financial reviews and interviews
- In customer surveys
Data we collect when you use our services. This includes the amount, frequency, type, origin and recipients:
- Payment and transaction data.
- Profile and usage data. This includes the profile you create to identify yourself when you connect to our internet services. It also includes other data about how you use those services. We gather this data from devices you use to connect to those services, such as computers and mobile phones, using cookies and other internet tracking software.
Data from third parties we work with:
- Companies that introduce you to us
- Financial advisers
- Card associations
- Credit reference agencies
- Fraud prevention agencies
- Payroll service providers
- Land agents
- Public information sources such as Companies House
- Agents working on our behalf
- Government and law enforcement agencies.
Do you ever share my personal information with third parties?
We may share your personal information with third parties working with us in order to carry out our work to you. We will only share your data if we have a lawful reason to do, so for example:
- Agents and advisers who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business
- Hodge approved service providers in relation to this application;
- Other members of the Group to which the Bank belongs, including its subsidiaries and associated companies;
- Regulators or authorities where required or permitted by law.
- HM Revenue & Customs, regulators and other authorities
- UK Financial Services Compensation Scheme
- Credit reference agencies
- Fraud prevention agencies
- Any party linked with you or your business’s products or services.
- Companies we have a joint venture or agreement to co-operate with
- Independent Financial Advisors
- Companies you ask us to share your data with.
We may need to share your personal information with other organisations to provide you with the product or service you have chosen:
- If you use direct debits, we will share your data with the Direct Debit scheme.
- If you have a secured loan or mortgage with us, we may share information with other lenders who also hold a charge on the property.
- If you require more information on who we send your personal data to we will provide this on request.
What are automated decisions and how do you use them in relation to my personal data?
Automated decision are decisions using your personal data undertaken by automated means. We sometimes use systems to make automated decisions based on personal information we have – or are allowed to collect from others – about you or your business.
This helps us to make sure our decisions are quick, fair, efficient and correct, based on what we know. These automated decisions can affect the products, services or features we may offer you now or in the future, or the price that we charge you for them.
Here are the types of automated decision we make:
|Pricing||We may decide what to charge for some products and services based on what we know.|
|Tailoring products and services||We may place you in groups with similar customers. These are called customer segments. We use these to study and learn about our customers’ needs, and to make decisions based on what we learn. This helps us to design products and services for different customer segments, and to manage our relationships with them.|
|Detecting fraud||We use your personal information to help decide if your personal or business accounts may be being used for fraud or money-laundering. We may detect that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. If we think there is a risk of fraud, we may stop activity on the accounts or refuse access to them.|
|Opening accounts||When you open an account with us, we check that the product or service is relevant for you, based on what we know. We also check that you or your business meets the conditions needed to open the account. This may include checking age, residency, nationality or financial position.|
Do I have any rights in relation to the way automated decision are made?
Yes, you have rights over automated decisions:
- You can ask that we do not make our decision based on the automated score alone.
- You can object to an automated decision, and ask that a person reviews it.
If you want to know more about these rights, please contact us.
We use some external bodies to undertake automated decisioning. For example:
Credit Reference Agencies
We carry out credit and identity checks when you apply for a product or services for you or your business. We may use Credit Reference Agencies to help us with this.
If you use our services, from time to time we may also search information that the CRAs have, to help us manage those accounts.
We will share your personal information with CRAs and they will give us information about you. The data we exchange can include:
- Name, address and date of birth
- Credit application
- Details of any shared credit
- Financial situation and history
- Public information, from sources such as the electoral register and Companies House.
We’ll use this data to:
- Assess whether you or your business is able to afford to make repayments
- Make sure what you’ve told us is true and correct
- Help detect and prevent financial crime
- Manage accounts with us
- Trace and recover debts
- Make sure that we tell you about relevant offers.
We will go on sharing your personal information with CRAs for as long as you are a customer. This will include details about your settled accounts and any debts not fully repaid on time. It will also include details of funds going into the account, and the account balance. If you borrow, it will also include details of your repayments and whether you repay in full and on time. The CRAs may give this information to other organisations that want to check credit status. We will also tell the CRAs when you settle your accounts with us.
When we ask CRAs about you or your business, they will note it on your credit file. This is called a credit search. Other lenders may see this and we may see credit searches from other lenders.
If you apply for a product with someone else, we will link your records with theirs. We will do the same if you tell us you have a spouse, partner or civil partner – or that you are in business with other partners or directors.
You should tell them about this before you apply for a product or service. It is important that they know your records will be linked together, and that credit searches may be made on them.
CRAs will also link your records together. These links will stay on your files unless one of you asks the CRAs to break the link. You will normally need to give proof that you no longer have a financial link with each other.
You can find out more about the CRAs on their websites, in the Credit Reference Agency Information Notice. This includes details about:
- Who they are
- Their role as fraud prevention agencies
- The data they hold and how they use it
- How they share personal information
- How long they can keep data
- Your data protection rights.
Here are links to the information notice for each of the three main Credit Reference Agencies:
Fraud Prevention Agencies (FPAs)
We may need to confirm your identity before we provide products or services to you or your business. Once you have become a customer of ours, we will also share your personal information as needed to help detect fraud and money-laundering risks. We use Fraud Prevention Agencies to help us with this.
Both we and fraud prevention agencies can only use your personal information if we have a proper reason to do so. It must be needed either for us to obey the law, or for a ‘legitimate interest’.
A legitimate interest is when we have a business or commercial reason to use your information. This must not unfairly go against what is right and best for you.
We will use the information to:
- Confirm identities
- Help prevent fraud and money-laundering
- Fulfil any contracts you or your business has with us.
We or an FPA may allow law enforcement agencies to access your personal information. This is to support their duty to detect, investigate, prevent and prosecute crime.
FPAs can keep personal information for different lengths of time. They can keep your data for up to six years if they find a risk of fraud or money-laundering.
The information we use
These are some of the kinds of personal information that we use:
- Date of birth
- Residential address
- History of where you have lived
- Contact details, such as email addresses and phone numbers
- Financial data
- Data relating to your or your businesses products or services
- Employment details
Automated decisions for fraud prevention
The information we have for you or your business is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
We and FPAs may process your personal information in systems that look for fraud by studying patterns in the data. We may find that an account is being used in ways that fraudsters work. Or we may notice that an account is being used in a way that is unusual for you or your business. Either of these could indicate a possible risk of fraud or money-laundering.
How this can affect you
If we or an FPA decide there is a risk of fraud, we may stop activity on the accounts or block access to them. FPAs will also keep a record of the risk that you or your business may pose.
This may result in other organisations refusing to provide you with products or services, or to employ you.
What happens if I choose not to give you my personal information?
We may need to collect personal information by law, or under the terms of a contract we have with you.
If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts or policies. It could mean that we cancel a product or service you have with us.
Any data collection that is optional would be made clear at the point of collection.
What personal information do you use for marketing purposes?
We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.
The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with.
We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
We will only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’ i.e.: when we have a business or commercial reason to use your information and we are doing it in a way that is best for you.
You can ask us to stop sending you marketing messages by contacting us at any time.
Whatever you choose, you’ll still receive statements, and other important information such as changes to your existing products and services.
We may ask you to confirm or update your choices if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.
If you change your mind you can update your choices at any time by contacting us.
How long will you keep my personal information?
We will keep your personal information for as long as you are a customer of Hodge.
After you stop being a customer, we may keep your data for up to 12 years for one of these reasons:
- To respond to any questions or complaints.
- To show that we treated you fairly.
- To maintain records according to rules that apply to us.
We may keep your data for longer than 12 years if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes.
How can I get a copy of the personal information you hold on me?
You can access your personal information we hold by submitting a Subject Access Request by writing to us at this address:
Data Protection Officer, Hodge, One Central Square, Cardiff, CF10 1FS.
What if the information you hold about me is incorrect? Letting us know if your personal information is incorrect
You have the right to question any information we have about you that you think is wrong or incomplete. Please contact us if you want to do this. If you do, we will take reasonable steps to check its accuracy and correct it.
What if you want us to stop using your personal information?
You have the right to object to our use of your personal information, or to ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.
There may be legal or other official reasons why we need to keep or use your data. But please tell us if you think that we should not be using it.
We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. In this situation, we would not use or share your information in other ways while it is restricted.
You can ask us to restrict the use of your personal information if:
- It is not accurate.
- It has been used unlawfully but you don’t want us to delete it.
- It not relevant any more, but you want us to keep it for use in legal claims.
- You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.
If you want to object to how we use your data, or ask us to delete it or restrict how we use it or, please contact us.
What happens if I want to withdraw the consent I have provided?
You can withdraw your consent at any time. Please contact us if you want to do so.
If you withdraw your consent, we may not be able to provide certain products or services to you. If this is the case, we will tell you.
How can I complain if I am not happy?
Please let us know if you are unhappy with how we have used your personal information.
You also have the right to complain to the Information Commissioner’s Office. Find out how to on their website https://ico.org.uk/concerns/.