We collect your personal data so that we can provide our products and services, manage our relationship with our clients and 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 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.
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 or want us to process the personal data that we consider is necessary and/or is required to meet our legal and regulatory obligations.
We generally process your personal data with your consent where required by law or where otherwise permitted or required by applicable law including for the following lawful reasons:
- Contract – when we’re performing contractual obligations under a contract to which you are a party
- Legal Obligation – when we’re required to comply with laws and regulations
- Life and Health Protection – when we’re processing personal data to protect an individual’s life and health
Purposes of Processing
We process your personal data for the following purposes, as relevant, depending on whether you have your own bank account with us or you represent, or are associated with, other individuals or organisations who bank with us.
Assessing and providing products and services to our clients (Legal basis: Consent, Contract or Legal Obligation)
- assessing eligibility and 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 law
- conducting credit checks and financial assessments
- setting credit limits for clients
- obtaining quotations for clients from third-party product providers, such as insurance products from insurance providers we partner with and assisting such providers to manage insurance products, including wealth management products.
Managing banking relationships and administering client accounts (Legal basis: Consent, Contract or Legal Obligation)
- establishing, continuing and managing banking relationship and account 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 and evaluating the products and services for clients
- effecting 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
- 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: Consent, Contract or Legal Obligation)
- managing authentication and user access controls for clients, for example, for online and mobile banking
- creating and maintaining our credit scoring models relating to clients
- conducting credit management activities, which includes maintaining client credit history and ensuring ongoing credit worthiness
- 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: Consent)
- 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 customer satisfaction surveys
- gathering insights by aggregating data from the use of our products and services and our applications to provide you with more tailored products and services.
Keeping you and our people safe (Legal basis: Consent, Legal Obligation or Life and Health Protection)
- 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 in order 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: Consent, Contract or Legal Obligation)
- conducting identity verification security checks against government and other official centralised databases, as required by law
- monitoring and recording our communications and screening applications and transactions in connection with actual or suspected fraud, financial crime or other criminal activities
- recording and monitoring your electronic communications with us, to the extent permitted by applicable law, 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: Consent or Legal Obligation)
- identifying and investigating compliance with our own Standard Chartered Group policies
- complying with relevant local and foreign law, regulations, rules, directives, judgments or court orders, requests, guidelines, government sanctions, embargo, reporting requirements, restrictions, demands 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
- following any voluntary guidelines or recommendations from industry bodies or associations.
Exercising our legal rights and conducting legal proceedings (Legal basis: Consent or Legal Obligation)
- 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
- 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, regulatory, or industry bodies or association related matter, action or proceeding.
Facilitating Standard Chartered Group mergers, acquisitions, and divestments (Legal basis: Consent)
- 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.