Where necessary we may extend the period for which we keep your data without updating this notice, for example, if we anticipate we may receive a legal claim or complaint after the period in this notice has elapsed.
General Enquiry about our accounts, products or services
If you do not request a My Money Review, My Money Enquiry or follow up, and do not give us your marketing preferences, as part of your enquiry, we will keep your personal data for 6 months from the date you make an enquiry. This is to allow time for you to open an account, product or service after the enquiry.
If you have had a My Money Review, My Money Enquiry or follow up to your enquiry, we will keep your personal data for 2 years from the date of your enquiry. This retention period is to provide an overview of our interactions with you and deal with your queries.
Joint accounts
If you have a joint account, we will keep information about that account at least until all other retention periods for any accounts held by you or the other account holder(s) have passed.
Savings
Savings Account
We will keep details of your savings account for 6 years after your account is closed to meet our legal and regulatory obligations and deal with your queries.
Savings Account - Application only
If you apply for a savings account and the application does not progress to opening, or no money is paid into it, we will keep your personal data for 6 months, to deal with your queries.
Mortgages
Mortgage Account
We will keep details of your mortgage account for 25 years after it has been paid off to meet our legal and regulatory obligations and to deal with your queries.
Mortgage - DIP or application only
If you complete a Decision in Principle (DIP) or apply for a mortgage account, and we have carried out a credit search, but this does not progress to account opening, we will keep your details, including results of the credit search for 6 years to help us better understand your DIP/mortgage application, to assess the affordability of the products and services you apply for and deal with your queries. We will keep these details, whether or not you proceed with a full mortgage application.
Protection, Investment and Savings products provided by third parties
We will keep details of the protection and investment products (e.g. family, income protection, endowment, life cover, term assurance, permanent health, critical illness, ISA, savings bonds, unit trusts, PEPs, pensions) you take out until the date of what would be your 120th birthday to deal with your queries.
If we are informed of your death, we will keep details of the protection, investment and savings products you held for 25 years after your death to deal with any queries.
Legacy Planning – wills, funeral planning, powers of attorney, executors
Will writing service
We will keep details of your request or referral for Will writing services indefinitely to help colleagues deal with any queries or concerns such as your will being contested.
Where we are made aware that you did not complete or sign a Will document we will keep details of your referral for 2 years to measure and manage colleague performance, provide management information and contact you where appropriate.
Funeral Plan
We will keep details of your Funeral Planning Services referral indefinitely to help colleagues deal with any queries or concerns.
Where we are informed of the death of a Funeral Plan holder, we will keep details of the plan, including details of the person who took out the plan, where this is different from the Funeral Plan holder, for 6 years after their death to deal with any queries or concerns.
Where we are made aware that you did not take out or have cancelled a Funeral Plan, we will keep details of your referral for 2 years from you requesting to take out or cancelling the plan to deal with any queries.
Power of Attorney (including Estate Management where applicable)
We will keep details of your referral, when you have requested that Power of Attorney/Estate Management documentation be produced, indefinitely to deal with your queries or concerns.
Where we are made aware that you did not go ahead with the request for Power of Attorney documentation, we will keep details of your referral for 2 years to deal with any queries.
Executor
We will keep details of Executors or a customer’s legal next of kin when they inform us of a customer’s death in line with the retention period(s) set for the accounts, products or services with us that they relate to, to meet our legal and regulatory obligations and deal with any queries.
Payment Services
We will keep details of the electronic payments you make and or receive, in line with the retention period for the accounts, products or services you have with us, to meet our legal and regulatory obligations and deal with any queries.
In accordance with the payment card industry data security standard (PCI-DSS), we do not hold full cardholder data on our systems.
Financial Advice
Financial Advice Investment Product
We will keep details of the Financial Advice Investment Product(s) you hold for 15 years after your product(s) have been closed to meet our legal and regulatory obligations and to deal with any queries.
Financial Advice - Pension transfers
We will keep details of pension advice relating to the transfer of Safeguarded Benefits (e.g. Guaranteed Annuity Rates/Guaranteed Minimum Pension) indefinitely to meet our legal and regulatory obligations and deal with any queries.
Fraud prevention
Fraud Prevention Agencies can hold your personal data for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to 6 years.
CCTV
We will keep CCTV images of our Head Office site for 3 months and of our branch network for up to 6 months, for crime prevention and public safety purposes.
Complaints
We will keep details of any complaint you make to us for a minimum of 6 years after the complaint has been resolved to meet our legal and regulatory obligations and to manage any escalation to The Financial Ombudsman Service (FOS). Until your complaint is resolved any other retention periods applicable to your relationship, accounts, products or services will be put on hold.
We will keep details of any complaint you make to FOS for a minimum of 6 years after the complaint has been resolved with FOS or after a FOS decision has been challenged to meet our legal and regulatory obligations.