We collect your personal data so that we can provide our products and services, manage our relationship with our clients and to operate our business. This is necessary when you hold your own bank account with us and also when you represent, or are associated with, other individuals, companies, businesses or organisations who bank with us, for example, if you act as a guarantor, employee, shareholder, director, officer or authorised person.
If you have or are associated with more than one account with Standard Chartered Group, we may link all your accounts and personal data to enable us to have an overall picture of our client relationships.
We generally process your personal data with your consent where required by law or where otherwise permitted or required by applicable laws, including for the following lawful reasons:
- Contract – when we’re performing contractual obligations
- Legal Obligation – when we’re required to comply with laws and regulations
- Legitimate Interest – when it’s within our legitimate interests for the purpose of processing
- Employment and Social Fields – when we are required to process data in relation to our rights or obligations in connection with employment or social security
- Legal Proceedings – when it is necessary for any legal proceedings, obtaining advice or defending legal rights.
What we use your personal data for is often referred to as our purposes of processing and these are detailed below. We may not be able to offer or provide our products and services if you do not provide us with the necessary personal data or do not want us to process the personal data that we consider is necessary and/or is required to meet our legal and regulatory obligations.
Purposes of Processing
We process your personal data for the following purposes, as necessary to provide relevant products and services, depending on whether you have your own bank account with us or you represent, or are associated with, other individuals, companies, businesses or organisations who bank with us.
Assessing and providing products and services to our clients (Legal basis: Contract, Legal Obligation or Legitimate Interest)
This includes:
- assessing eligibility, merits and/or suitability of product and service applications for clients; we may retain a record of the application if our eligibility criteria are not met
- assessing your suitability as an individual guarantor
- conducting relevant due diligence and know-your-customer (KYC) checks as required by applicable laws
- conducting credit checks and financial assessments as required by applicable laws and regulations
- setting credit limits for clients
- obtaining quotations, assisting with applications and interacting with strategic referral partners on behalf of clients for co-branding and other third-party products and services, such as insurance and wealth management products
- opening accounts.
Managing banking relationships and administering client accounts (Legal basis: Contract, Legal Obligation, Legal Proceedings or Legitimate Interest)
This includes:
- establishing, continuing and managing client banking relationships and accounts with us or, where applicable, any member of the Standard Chartered Group
- providing clients with appropriate access to our products and services, such as our online and mobile banking platforms
- operating, providing, reviewing and evaluating the products and services, offered by or through us or any member of Standard Chartered Group, to fulfil our contractual obligations with clients for products and services
- effecting and verifying transactions and acting on instructions or requests, such as transferring money between accounts and making payments to third parties for clients
- maintaining up-to-date records of authorised persons and signature lists
- maintaining statements detailing the amount of indebtedness owed by you to us and by us to you
- administering, for example, credit facilities or loans for clients
- maintaining contact information
- responding to questions or managing any complaints, including monitoring social media conversations and posts to identify conversations, sentiments, and complaints about the Standard Chartered Group
- issuing notifications about changes to the terms and conditions of our products and services
- recording our communications for record-keeping and evidential purposes including online messages, email and telephone
- contacting clients relating to the products and services we are providing
- facilitating open banking for clients, including with Account Information Service Providers (AISPs).
Operating our business (Legal basis: Contract, Legal Obligation or Legitimate Interest)
This includes:
- managing authentication and user access controls for clients, for example, for online and mobile banking
- audits of our business operations
- creating and maintaining our credit scoring models relating to clients
- conducting relevant credit management activities, which includes maintaining client credit history for present and future reference, updating credit bureaus and credit reference agencies and ensuring ongoing credit worthiness and credit checks
- assisting other banks and third parties recover funds that have entered client accounts as a result of erroneous payments
- engaging in business operational management, such as performing administrative tasks relating to the products and services we provide, monitoring and reporting of our financial portfolio, risk management activities, audits and ensuring operation and security of our communications and processing systems, systems development and testing, business planning and decision-making.
Improving our products and services to our clients (Legal basis: Legitimate Interest or Consent)
This includes:
- developing, testing and analysing our systems, products and services
- monitoring and recording our communications with you, for example, phone calls, for training and quality purposes
- conducting market research and customer satisfaction surveys
- designing our products and services for your use, for example credit cards
- conducting demographic analytics and gathering insights by aggregating data such as behavioural data from the use of our products and services and our applications to provide you with more tailored products and services.
For further information on direct marketing, please refer to ‘When do we conduct direct marketing?’ section of this privacy notice.
Keeping you and our people safe (Legal basis: Legal Obligation, Employment and Social Fields, Legal Proceedings or Legitimate Interest)
This includes:
- conducting identity verification security checks for building access
- using CCTV surveillance recordings at our branches, premises and ATMs for the purposes of preventing and detecting fraud and/or other crimes, such as theft
- investigating and reporting on incidents or emergencies on our properties and premises
- for the security of our systems and networks to keep your data safe and confidential
- for other health and safety compliance purposes
- monitoring social media conversations and posts to protect clients from sharing data publicly that could be used for fraud.
Detecting, investigating and preventing financial crimes (Legal basis: Contract, Legal Obligation, Legal Proceedings or Legitimate Interest)
This includes:
- meeting or complying with Standard Chartered Group policies, including identifying individuals and performing investigative procedures, measures or arrangements for sharing data and information within the Standard Chartered Group
- any other use of data and information in accordance with any group-wide programmes for compliance with sanction or prevention or detection of money laundering, terrorist financing or other unlawful activities
- conducting identity verification security checks against government and other official centralised databases, as required by law
- monitoring and recording voice and electronic communications and screening applications and transactions in connection with actual or suspected fraud, financial crime or other criminal activities, for example to detect unusual transaction behaviour
- recording and monitoring voice and electronic communications with us, to the extent permitted by applicable laws, to ensure compliance with our legal and regulatory obligations and internal policies
- conducting checks against government and non-government third parties’ fraud prevention and other financial crime prevention databases to prevent money laundering, terrorism, fraud and other financial crimes, to protect you, our clients and the integrity of the financial market. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services or employment to you.
Complying with applicable laws, regulations and other requirements (Legal basis: Legal Obligation or Legitimate Interest)
This includes:
- meeting or complying with Standard Chartered Group policies, including identifying individuals and performing investigative procedures, measures or arrangements for sharing data and information within the Standard Chartered Group
- complying with relevant local and foreign law, regulations, rules, directives, judgments or court orders, requests, guidelines, government sanctions, embargos, reporting requirements, restrictions, demands from or agreements with any authority (including domestic or foreign tax authorities), court or tribunal, enforcement agency or exchange body in any relevant jurisdiction where the Standard Chartered Group operates. For example, we may share personal data relating to your personal bank account with a local tax authority in accordance with applicable laws or regulations. The local tax authority may share or may require us to share such information with other overseas tax authorities in accordance with applicable laws or regulations (for example, tax law and regulation relating to automatic exchange of financial account information). We may need to collect extra information from you for such purpose to comply with applicable laws or regulations
- following any voluntary guidelines or recommendations as may be updated from time to time issued by legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers in any relevant jurisdiction where the Standard Chartered Group operates.
Exercising Standard Chartered Group’s legal rights and conducting legal proceedings (Legal basis: Legal Obligation, Legal Proceedings or Legitimate Interest)
This includes:
- tracing and exercising our rights and protecting ourselves against harm to our rights and interests
- retaining records as may be necessary as evidence for any potential litigation or investigation
- recovering debts and arrears
- conducting litigation to enforce our rights or the rights of any other member of the Standard Chartered Group
- obtaining professional advice
- investigating or making an insurance claim
- responding to any insurance related matter, action or proceeding
- defending or responding to any current or prospective legal, governmental or quasi-governmental, regulatory, or industry bodies or associations related matter, action or proceeding or for establishing, exercising or defending legal rights.
Facilitating Standard Chartered Group mergers, acquisitions, and divestments (Legal basis: Legitimate Interest)
This includes:
- evaluating our business and providing continuity of services to you after a transfer of our business as a result of a merger, acquisition, sale or divestment
- enabling an actual or potential assignee (a party who receives the transfer of a right from another party under a contract) of all or any part of our business and/or asset or participant or sub-participant of our rights in respect of the data subject, to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation.
