Data Protection and Privacy Statement

If you are reading this Privacy Statement on behalf of a body corporate/business enterprise which maintains/maintained contractual relationship with SCB (as defined below), this Privacy Statement is intended to be addressed to, without limitation, the individual guarantor, obligor, corporate officers (e.g. authorised signatories/dealer and company secretary), directors, shareholders, beneficial owners (e.g. sole proprietor and partners) of the body corporate/business enterprise (the “Relevant Individuals”) and “you” shall be construed accordingly to mean the Relevant Individuals. Please assist to make available this Privacy Statement to the Relevant Individuals in your body corporate/business enterprise.

This Privacy Statement relates to the collection, use and disclosure of personal data, including special or sensitive personal data, by any member of the Standard Chartered Group (“SCB”, “we” or “our”). Personal Data is information relating to an individual (“you” or “your”).

The data controller of your personal data is Standard Chartered Bank Nigeria Limited, whom you have or may have a relationship with or with whom an account is maintained that you are a security provider for. SCB Head Office functions may also be the controller of your Personal Data. A list of SCB entities can be found at https://www.sc.com/en/our-locations/

Personal data comprises all the details SCB holds or collects about you, directly or indirectly, your transactions, transactions you effect, financial information, interactions and dealings with SCB, including information received from third parties, the public domain, collected through use of our website, cookies, and our electronic banking services.

If you have or are party to more than one account with SCB, including to a Corporate and Institutional Banking relationship, we will link all your accounts and personal data to enable us to have an overall picture of your relationship with us.

If you do not provide us with personal data we need to meet our legal and regulatory obligations or to enter into an agreement with you we may not be able to provide you with the products or services you have requested.

Purposes for which we may process your Personal Data

To enable us to fulfill the contract between us for the products or services you have requested, we need to process your personal data for purposes including the following:

1. processing applications for products and services, effecting payments, transactions, updating records and completing instructions or requests;
2. providing products and services (including electronic banking services);
3. assessing suitability for products and services;
4. credit assessment, including conducting credit checks and setting credit limits;
5. operational purposes;
6. statistical purposes;
7. establishment, continuation and management of banking relationships and accounts;
8. surveillance of premises and ATMs.

For some purposes in connection with the service you have requested, we have a legal or regulatory obligation to process your Personal Data. These purposes include:

1. the prevention, detection, investigation and prosecution of crime in any jurisdiction (including, without limitation, money laundering, terrorism, fraud and other financial crime);
2. identity verification, government sanctions screening and due diligence checks;
3. enforcing obligations, including without limitation the collection of amounts outstanding from you and your provision of security for the facilities;
4. to comply with local or foreign law, regulations, directives, judgments or court orders, government sanctions or embargoes, reporting requirements under financial transactions legislation, and demands of any authority, regulator, tribunal, enforcement agency, or exchange body.

We may also process your Personal Data in line with any voluntary codes; to effect agreements between any member of the Standard Chartered Group and any authority, regulator, or enforcement agency; to comply with our internal policies and good practice standards where it is in our legitimate interest to do so.

We may also process your Personal Data where it is in our legitimate interests to seek professional advice, including, in connection with any legal proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending legal rights.

Consent

You accept this privacy policy and give your consent when you access our platforms, or use our services, content, features, technologies or functions offered on our website, digital platforms or visit any of our offices for official or non-official purposes (collectively the “SCB Business”). We will ensure you understand and consent to any new ways in which your information is handled whenever we introduce any new products and services. We may amend this privacy policy at any time by posting a revised version on our website or placing such notice at conspicuous points at our office facilities.

What personal data we collect about you and the source

Personal data that we will collect from you includes but not limited to:

• full name
• identification number
• date of birth
• gender
• ethnic
• number of dependents
• contact details (including address, telephone number, e-mail address)
• employment and income details
• financial commitments
• results of credit checks

We may also collect your personal data from other sources, including but not limited to credit bureaus, credit reference agencies, your employers, your guarantors and your joint account holders.

To whom we may disclose Personal Data

Any member of SCB, including our officers, employees, agents and advisers, may disclose your Personal Data to any of the following parties for any of the purposes specified above:

1. any member of the Standard Chartered Group anywhere in the world, including any officer, employee, agent or director;
2. professional advisers (including auditors), third party service providers, agents or independent contractors providing services to support SCB’s business;
3. our business alliance partners who may provide their product or service to you;
4. a merchant or a member of a card association where the disclosure is in connection with use of a card;
5. upon your death or mental incapacity, your legal representative and their legal advisers, and a member of your immediate family for the purpose of allowing him/her to make payment on your account;
6. any security provider or any person authorised to operate your account and to act on your behalf in giving instructions, to perform any other acts under our banking agreement or use any product;
7. any person to whom disclosure is allowed or required by local or foreign law, regulation or any other applicable instrument;
8. any court, tribunal, regulator, enforcement agency, exchange body, tax authority, or any other authority (including any authority investigating an offence) or their agents;
9. any debt collection agency, credit bureau or credit reference agency, rating agency correspondents, insurer or insurance/Takaful broker, direct or indirect provider of credit protection and fraud prevention agencies;
10. any financial institution to conduct credit checks, anti-money laundering related checks, for fraud prevention and detection of crime purposes;
11. anyone we consider necessary to facilitate requests for services or applications for products with any member of the Standard Chartered Group;
12. anyone we consider necessary in order to provide services in connection with a product;
13. any actual or potential participant or sub-participant in relation to any of our obligations in respect of any banking agreement, assignee, novatee or transferee (or any officer, employee, agent or adviser of any of them); located in any jurisdiction.

Security

Personal Data may be transferred to, or stored at, a location outside of your country of residence. The security of your personal data is important to us. SCB has technical and organisational security measures in place to safeguard your personal data. When using external service providers, we require that they adhere to security standards mandated by SCB. We may do this through contractual provisions, including any required by a privacy regulator, and oversight of the service provider. Regardless of where personal data is transferred, we take all steps reasonably necessary to ensure that personal data is kept securely.

You should be aware that the Internet is not a secure form of communication and sending us any personal data over the Internet carries with it risks including the risk of access and interference by unauthorised third parties. Information passing over the Internet may be transmitted internationally (even when sender and recipient are located in the same country) via countries with weaker privacy and data protection laws than in your country of residence.

Other Terms and Conditions

There may be specific terms and conditions in our banking and product agreements that govern the collection, use and disclosure of your personal data. Such other terms and conditions must be read in conjunction with this Privacy Statement.

Retention

We retain your personal data in line with our legal and regulatory obligations and for business and operational purposes.

Automated decisions and profiling

We may use profiling, including behavioural analysis, to assist us to provide you with better services, to make decisions and to prevent money laundering, terrorism, fraud and other financial crime, for example using profiling may help us to try and detect whether use of your credit card may be fraudulent. If any profiling will result in an automated decision relating to you, we will let you know and you will have the right to discuss the decision with us.

Marketing

We may use your Personal Data:

1. to conduct market research and surveys with the aim of improving our products and services;
2. for marketing purposes, promotional events, competitions and lucky draws.

We process your Personal Data for these purposes because it is in the interest of our business to do so with the intention of improving our products and services and generating business. We will not send you marketing material if you have specifically asked us not to do so. You have the right to opt out of receiving marketing material at any time. To do so please contact your branch or relationship manager. If you  ask us not to send you marketing material or other promotional or research material, we may need to retain a record that you have asked us not to do so to ensure that you do not receive anything further.

Monitoring

To the extent permitted by law, we may record and monitor your electronic communications with us to ensure compliance with our legal and regulatory obligations and internal policies for the purposes outlined above.

Your Rights

Subject to applicable law, regulations and/or banking industry guidelines, you have the following rights in addition to those conferred by law and regulation:

Access

To request a copy of the personal data processed in relation to you. Where applicable law permits, SCB may charge a fee for this.

Correction

To request that we correct your personal data. You can do this at your branch or through your relationship manager.

Erasure

To ask us to delete your personal data, for example if we no longer have a valid reason to process it.

Object

To object to how we process your personal data. This does not mean you can decide or choose how we process your personal data other than in relation to marketing. If you have any concerns about how we process your personal data, please discuss this at your branch or with your Relationship Manager. We may not be able to offer you services if you do not want us to process the personal data we consider it necessary to process to provide the services.

Restriction

To restrict how your personal data is processed in certain cases, such as when the accuracy of your Personal Data is contested. If you have any concerns about how we process your Personal Data, please discuss this at your branch or with your Relationship Manager.

Portability

To request a copy of the personal data you have given to us in a machine-readable format.

Cookies

Please see our separate Cookie Policy at https://www.sc.com/en/cookie-policy/

Privacy Statement for visitors to our website or premises and individuals who do not have a relationship with the Bank either as a client or through a client relationship

This Privacy Statement relates to the collection, use and disclosure of personal data, including special or sensitive personal data, by any member of the Standard Chartered Group (“SCB”, “we” or “our”). Personal Data is information relating to an individual (“you” or “your”).

Personal data comprises all the details SCB holds or collects about you, directly or indirectly, your transactions, transactions you effect, financial information, interactions and dealings with SCB, including information received from third parties, the public domain, collected through use of our website, cookies, and our electronic banking services.

Visitors to our website

We collect personal data which you voluntarily provide when visiting our website. We may also collect personal data collected through cookies and similar technology – for further information on our use of cookies please read our cookie policy.

When visiting our website, you may choose to provide personal data to us for the following purposes:

• Subscribe to our publications and research
• Contact us for information, either through an online form or through email

When you provide personal data for the above purpose, we will only use your personal data for the purpose provided and for statistical analysis. You can unsubscribe from receiving our publications and research at any time.

Visitors to our premises

We collect personal data about visitors to our premises. This may include your full name, the name of any company you represent, telephone number, building access data from access cards and images held, for example, on CCTV systems or temporary access cards.

We process your personal data, where it is in our legitimate interests, for the purposes of:

1. visitor, contractor and employee health and safety;
2. security of visitors, contractors, employees and Group premises and assets;
3. prevention, detection, investigation and prosecution of crime;
4. compliance with our internal policy requirements.

We may also process your personal data to comply with our legal and/or regulatory obligations including financial crime and any external or internal investigations.

When your personal data is provided for the above purposes, we will only use your personal data when necessary for those purposes.

Any member of SCB, including our officers, employees, agents and advisers, may disclose your personal data to any of the following parties for any of the purposes specified above:

1. Any member of the Standard Chartered Group anywhere in the world, including any officer, employee, agent or director;
2. Professional advisers (including insurers and legal advisers), third party service providers, agents or independent contractors providing services to support SCB’s business;
3. Any person to whom disclosure is allowed or required by local or foreign law, regulation or any other applicable instrument;
4. Any court, tribunal, regulator, enforcement agency or any other authority (including any authority investigating an offence) or their agents;
5. Anyone we consider necessary in order to provide services to SCB located in any jurisdiction.

Non client payees

We may be asked by a client to effect a transaction to the benefit of an individual who may not have a relationship with SCB. The personal data processed will generally be limited to your name, bank account number and contact details. The data controllers will be the entity that effected the transaction and our Head Office. We will determine if a payment beneficiary has a relationship with SCB. We cannot effect a payment if we are not provided with personal data we need to meet our legal and regulatory obligations.

We may process your personal data in line with our legal and/or regulatory obligations including:

1. the prevention, detection, investigation and prosecution of crime in any jurisdiction (including, without limitation, money laundering, terrorism, fraud and other financial crime);
2. government sanctions screening;
3. to comply with local or foreign law, regulations, directives, judgements or court orders, government sanctions or embargoes, reporting requirements under financial transactions legislation, and demands of any authority, regulator, tribunal, enforcement agency, or exchange body.

We may also process your Personal Data where it is in our legitimate interests, to seek professional advice, including, in connection with any legal proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending legal rights.

Any member of SCB, including our officers, employees, agents and advisers, may disclose your Personal Data to any of the following parties for any of the purposes specified above:

1. any member of the Standard Chartered Group anywhere in the world, including any officer, employee, agent or director;
2. professional advisers (including auditors), third party service providers, agents or independent contractors providing services to support SCB’s business;
3. any person to whom disclosure is allowed or required by local or foreign law, regulation or any other applicable instrument;
4. any court, tribunal, regulator, enforcement agency, exchange body, tax authority, or any other authority (including any authority investigating an offence) or their agents;
5. anyone we consider necessary in order to provide services in connection with a product;

located in any jurisdiction.

Sponsorship and Donations

When deciding whether to enter into a sponsorship agreement or make a donation, we may process personal data on the person or those connected with the person who may be sponsored or to whom a donation may be made in line with our legal and/or regulatory obligations including:

1. the prevention, detection, investigation and prosecution of crime in any jurisdiction (including, without limitation, money laundering, terrorism, fraud and other financial crime);
2. government sanctions screening;
3. to comply with local or foreign law, regulations, directives, judgements or court orders, government sanctions or embargoes, reporting requirements under financial transactions legislation, and demands of any authority, regulator, tribunal, enforcement agency, or exchange body.

We may also process your Personal Data where it is in our legitimate interests, to seek professional advice, including, in connection with any legal proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending legal rights.

Any member of SCB, including our officers, employees, agents and advisers, may disclose your Personal Data to any of the following parties for any of the purposes specified above:

1. any member of the Standard Chartered Group anywhere in the world, including any officer, employee, agent or director;
2. professional advisers (including auditors), third party service providers, agents or independent contractors providing services to support SCB’s business;
3. any person to whom disclosure is allowed or required by local or foreign law, regulation or any other applicable instrument;
4. any court, tribunal, regulator, enforcement agency, exchange body, tax authority, or any other authority (including any authority investigating an offence) or their agents;

located in any jurisdiction.

Security

Personal Data may be transferred to, or stored at, a location outside of your country of residence, which may not provide the same statutory protections for your personal data. The security of your personal data is important to us. SCB has technical and organisational security measures in place to safeguard your personal data. When using external service providers, we require that they adhere to security standards mandated by SCB. We may do this through contractual provisions, including any required by a privacy regulator, and oversight of the service provider. Regardless of where personal data is transferred, we take all steps reasonably necessary to ensure that personal data is kept securely.

You should be aware that the Internet is not a secure form of communication and sending us any personal data over the Internet carries with it risks including the risk of access and interference by unauthorised third parties. Information passing over the Internet may be transmitted internationally (even when sender and recipient are located in the same country) via countries with weaker privacy and data protection laws than in your country of residence.

Retention

We retain your personal data in line with our legal and regulatory obligations and for business and operational purposes.

Monitoring

To the extent permitted by law, we may record and monitor your electronic communications with us to ensure compliance with our legal and regulatory obligations and internal policies for the purposes outlined above.

Your Rights

Subject to applicable law, regulations and/or banking industry guidelines, you may have the following rights in addition to those conferred by law and regulation:

Access

• To request a copy of the personal data processed in relation to you. SCB may be allowed by law to charge a fee for this.

Correction

• To request that we correct your personal data.

Erasure

• To ask us to delete your personal data, for example if we no longer have a valid reason to process it.

Object

• To object to how we process your personal data. This does not mean you can decide or choose how we process your personal data other than in relation to marketing.

Restriction

• To restrict how your personal data is processed in certain cases, such as when the accuracy of your Personal Data is contested.

The Data protection Officer can be contacted at:

Nigeria.DPO@SC.com
Standard Chartered Bank, Nigeria
142 Ahmadu Bello Way
Victoria Island
Lagos

If you have a complaint in relation to the processing of your Personal Data and you are not happy with the way we deal with it, please discuss this at your branch or with your Relationship Manager, or contact the Data Privacy Officer.

You also have the right to complain to the data protection authority currently the National Information Technology Development Agency (NITDA), or if you are located within the European Union, the UK Information Commissioner. Details can be provided by emailing privacy@sc.com

Where you have concerns relating to the processing of your personal information by Standard Chartered Bank, or require any clarification on this policy, please notify us through or contact details provided below:

Email: Nigeria.DPO@SC.com

We will respond to your concerns within 30 days of receiving your notice.

This Privacy Policy may be updated from time to time and you are advised to visit this site regularly to check for any amendments. This policy was last updated on 01/02/2021.

Please see our separate Group Recruitment Privacy Statement https://www.sc.com/en/privacy-policy

Our Privacy Policy does not apply to third-party websites where our online advertisements are displayed or to linked third-party websites which we do not operate or control.