Privacy Policy

Privacy Policy

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Our commitment:

At Conister Bank Limited (“the Bank”), we are aware of the trust you place in us and our responsibility to protect your privacy and keep your personal data secure in accordance with Data Protection legislation.

This privacy notice covers:

• How and why we process your personal information;
• The sources of information about you;
• The parties we may disclose it to;
• How long we will retain your information;
• What rights you have in respect of your personal data; and
• How you can contact us with any further queries or concerns.   

The Data Controller:

Conister Bank Limited is the Data Controller for the purposes of the Data Protection Act 2018 and in relation to all the personal data provided to us. The primary legal basis for which we process this personal data, is for the performance of contracts we enter into (or may enter into) with you for our products and services. 

Why do we collect personal information?

We collect your personal information for the following purposes:

• It is necessary to consider applications from potential customers for our products and services, or for considering 3^rd party service agreements, in preparation for the entering into contracts;
• It is necessary to provide existing customers with our goods/services, to perform obligations under agreements for goods/services and maintain ongoing relationships with our customers;
• To manage any third party arrangements required by the Bank in order to run our business and provide you with goods/services; 
• To consider any applications for employment or sponsorship; and
• To comply with our legal and regulatory obligations as a regulated financial services provider.  

Your personal information is only collected and used for the purpose(s) it was provided for, and of which you were aware at the time your information was supplied to us.  We will limit the collection of your personal information to only that which is needed in order to satisfy the intended purpose.

It is ultimately your decision as to whether to provide us with any of your personal information, however, please note that if you fail to provide information we have requested, or you fail to provide accurate information, we may not be able to engage with you further.

What information do we collect and how do we collect it? 

In order to fulfil the purposes above, we will need to collect your personal information. We collect it from you when you initially provide it to us, every time you contact us during the administration of your relationship with us, and from additional sources such as background checks and/or references. Information is collected when you meet with us, complete forms, correspond with us, telephone us, or send us an email. We may also get your personal information from an intermediary such as for example, a car dealership if you are applying for vehicle finance or financial advisor if you have engaged them to find you a suitable savings account provider.      

This information can include all, or a combination of any of the items listed below:

• General personal details including your name, date of birth, place of birth, nationality, gender, marital status;
• Your contact details (address, telephone numbers, e-mail);
• Employment details such as employment status, employer contact details, and benefits and salary information;
• Information about previous loans or accounts you may have had relevant to your current requirements.
• Financial details such as bank account details and/or tax information;
• Character references if you are applying for a job with us;
• Publicly available information (generally obtained through internet searches) such as news articles or public register information which is obtained from background searches or reference checks.  

Sensitive Information:

Certain types of personal information are classed as “sensitive” under the Data Protection legislation, or otherwise referred to as “special categories” of data. This includes information about your health, race, ethnic origin, political opinions, religious or philosophical beliefs, sexual orientation, trade union membership and genetic and biometric data.

We do not need to collect your sensitive personal data during the normal course of our business. However, sometimes we may indirectly come across sensitive information such as your health data. For example, if you have a deposit account with us that is subject to a court registered Enduring Power of Attorney, we will be aware of the fact that a data subject may have mental health issues requiring the use of the Power of Attorney, and thus we have indirect information relating to a customer’s health. In order to be able to process any sensitive personal data, we will need your consent. In the event we are likely to (or do) come into possession of your sensitive personal data, we will contact you separately to seek your consent for its processing.       

How do we use your personal information?

We store and process the personal information that you (or third parties) have provided to us in any or all of the following ways:

• To conduct credit searches and background checks if you are applying for our products or services;
• To consider any application for employment or sponsorship you may have submitted;
• Administrative in order to allow us to perform our obligations under any loan agreement or account terms and conditions, or employment contract you have entered into with us;
• To supply you with information about product(s) and/or service(s) that either you have requested from us, or wish to provide to us;
• To manage our relationship with you;
• For general business purposes and to prepare management and accounting information necessary for the conduct of our business, including audit;
• For the prevention and detection of crime, including AML purposes, fraud detection and debt collection; and
• To comply with any and all statutory responsibilities.

Information you submit through our website may be held and processed by our Internet Service Provider, but it is only held and processed on our behalf and under our strict instruction.

Disclosure of Personal Information:

During the term of your relationship with us we may disclose your personal information to any of the following parties to allow us to properly manage our relationship with you:

• To screening agencies, credit reference agencies and fraud prevention agencies to enable us to conduct credit and background checks; (for further information see below);
• To organisations who may record, use and give out information to other lenders or insurers in order to make decisions about financial products;
• In respect of consumer loans to UK customers, to your credit intermediary (if you used one) and/or our UK based finance partners. (For further information about this please contact us using the contact details at the back of this document);
• To our insurers for the purpose of acquiring appropriate insurance cover in relation to specific products and/or services that we offer;
• To persons acting as our agents or on our behalf under a strict code of confidentiality where we outsource functions relating to our products and services (for example, our IT system providers, document storage and archiving companies etc.);
• To anyone we transfer or may transfer our rights and duties under your agreement(s) with us;
• Back to you during the course of your relationship with us;
• If you are a current or former employee, to future employers who seek references about you (who will require your consent to do this); or
• To legal or regulatory bodies (such as the Isle of Man Financial Services Authority) as required by law or regulation.

Otherwise we will keep all of your personal information confidential unless you give us consent to transfer it to a third party.

It is not normally necessary during the usual course of business to transfer your personal data outside of the Isle of Man or the UK, however, in the event it is necessary, it will be done so in accordance with the requirements of Data Protection legislation. These requirements include the provision that the recipient of your personal data must have the same level of protection in place as you are entitled to on the Isle of Man or in the UK. We will advise you in the event that your personal data is to be transferred in this manner.

The exception to this is, if you as a customer live outside the Isle of Man, UK or the EEA and we are sending your personal information back to you, this will be necessary in order to communicate with you and for providing you with our goods and services. Our e-mails to you are subject to encryption and any sensitive documentation will be sent via registered mail.     

Credit Reference Agencies:

In considering whether to enter into any agreement with you for goods and/or services, we will search your record and that of any joint applicant or any guarantor using standard public searches and credit reference agencies, these may include credit scoring. The credit reference agencies will add to their record about you and any joint applicant and any guarantor. The details of our search and your application will be seen by other organisations that make searches using the same credit reference agencies. 

We will also add to your record held with the credit reference agencies the details of any loan agreement you enter into with us. This includes the payments you make under it and any default or failure to keep to its terms.

This and other information about you and those with whom you are linked financially may be used to make credit decisions about you and other members of your household.

We currently use the following 3 credit reference agencies. For further information regarding how they will process your information, please refer to the links provided:

• CallCredit -  www.callcredit.co.uk/crain
• Equifax - www.equifax.co.uk/crain
• Experian - www.experian.co.uk/crain

Fraud Prevention Agencies:

We may share your personal information with fraud prevention agencies if we feel fraud has been or might be committed. These agencies collect, maintain and share data on known and suspected fraudulent activity for the purposes of fraud prevention. These records may be searched and shared with other organisations by the fraud prevention agencies.

We have a legal obligation to report suspected fraud to law enforcement agencies, and we are not permitted to share the detail of any disclosure with you.

The fraud prevention and law enforcement agencies we share data with are: 

• Isle of Man Financial Intelligence Unit;
• CallCredit;
• Equifax;
• Experian;
• Dun & Bradstreet.

Please telephone or write to us at the address stated below if you would like further details of the fraud prevention agencies. 

How long do we retain your personal information?

We are permitted by law to retain your information for as long as is necessary in relation to the purposes for which the information was originally provided. This includes our legal requirement to hold some information for at least six years following the termination of a customer relationship or transaction.

We will hold the personal information of our customers, your accounting records, client due diligence (CDD) and transaction records for a minimum of six years, except where records are required for investigation by law enforcement, where they will be retained for as long as required by the Constable or competent authority.

If you have been declined a loan or deposit account with us, we will retain your personal information for a maximum of 3 months from the date we received it, unless you give us permission to retain it for longer.

If you have been unsuccessful in applying for a job with us, we will retain your information for a maximum of 6 months unless you give us permission to retain it for longer.  

Once your information is no longer necessary in accordance with the above, it shall be destroyed in line with Data Protection legislation. 

Your Rights:

Under Data Protection legislation you have the following rights free of charge:

1.    Access to Personal Data

Subject to exceptions detailed in Data Protection legislation, you have a right of access to all personal data we hold about you. If you wish to exercise this right, or you have any questions regarding your personal data, please write to the Data Protection Officer at the address overleaf. We will respond within one month from receipt of a valid request, and in any event, without undue delay.

2.    Automated Decision Making:

If you are applying for a loan with us, your application may be decided using purely automated decision making technology. This means that the personal information you provide (or is collected through background and credit checks) is fed through our computer systems and marked against a list of parameters we are prepared to accept if your loan application is to be successful. If your information does not meet pre-programmed criteria, your loan application may be declined. The decision as to whether to grant you a loan is therefore “automatically determined”.

You have the right to request that your application is assessed instead by a physical person. If you would like to exercise this right, or you would like further information about this, please write to the Data Protection Officer at the address overleaf.

3.    Rectification

You have the right to the rectification of inaccurate data, and to obtain completion of incomplete personal data. To correct or amend your personal data, please contact the Data Protection Officer at the address overleaf with the details. We will make the required changes as soon as possible.

4.    Erasure

In certain situations you have the right to request that your personal data is erased, however, there are limitations to this right.

Examples of grounds for exercising your right to erasure include:

• Personal data is no longer necessary for the purpose of the performance of a contract between us and you;
• Where data has been unlawfully processed;
• Where data has to be erased to comply with a legal obligation;
• Where a right to object to direct marketing or the right to object to processing has been exercised.

Examples of limitations to your right of erasure include:

• It is necessary for the performance of a contract between us and you;
• Our compliance with legal obligations to retain client records for certain periods of time (as detailed above); and
• Establishment, defence or exercise of legal claims.

 5.    Restriction of Processing

You have the right to restrict our processing of your personal data in the following circumstances:

• If you contest the accuracy of personal data processed by us, (we may restrict processing for a limited period to enable  us to verify the accuracy and amend the data as necessary);
• We no longer require your information for the purposes we originally obtained it;
• We have no legitimate grounds for processing your information or your information has been processed unlawfully.

If you wish to exercise this right please contact the Data Protection Officer at the address overleaf with the full details.

6.    Data Portability

You have a right to receive your personal information that you have provided to us, in a structured, commonly used and machine readable format. You also have a right to have this personal data transmitted to another data controller (i.e. another business), where technically feasible to do so.

7.    Right to Object

You have the right to object to us processing your personal data in the following circumstances:

• For direct marketing purposes;
• Profiling in relation to direct marketing.

8.    Right to Lodge a Complaint

If you have a complaint regarding the way we are processing your personal data, please address it with us in the first instance in the hopes that we will be able to resolve the matter with you. However, if you do not want to address your concerns to us, or we have failed to satisfactorily respond to your data protection complaint, you have the right to complain to the Data Protection Supervisor. The contact details are below:

• Isle of Man:

Information Commissioner
First Floor
Prospect House
Prospect Hill
Douglas
Isle of Man
IM1 1ET
 
Tel: +44(0) 1624 693260

• United Kingdom:

Information Commissioners Office
Wycliffe House
Water Lane
Wilmslow
SK9 5AF

Tel: +44(0) 303 123 1113

Marketing:

If you wish to receive information about our products or services please let us know by any of the contact options provided below.

Cookies:

Our website uses a number of cookies to store data on our visitor's computers.

Cookies are text files which identify users’ to the Conister server. Our cookies do not store any personal or sensitive information, or anything that makes you personally identifiable to us. They are used for essential functionality such as security when processing form data or for analytics which helps us use anonymous visitor data to gain a better understanding of how people use our website.

For further information, please refer to our Cookie Policy.

What is aggregate information?

Aggregate information is used to show us the total number of visits to our website and which parts of the site are used and most. Aggregate information does not identify individuals, as it does not contain any personal data. This information helps us in developing our website and improving the service we offer you.

The Data Protection Officer and Contact Details:

If you have any questions or concerns regarding this notice or you wish to exercise your rights, please contact us, addressing your query to the Data Protection Officer:

Writing: Conister Bank Limited, Clarendon House, Victoria Street, Douglas, Isle of Man, IM1 2LN

Telephone: +44 (0)1624 694694

Email: data@conisterbank.co.im

CBL/54/WPN/V4- Jan2019