Privacy Policy

We are committed to protecting your privacy and keeping your personal information secure.

Skipton International are a wholly owned subsidiary of Skipton Building Society.

‘We’, ‘our’, ‘us’ and ‘Skipton’ in this Privacy Notice means Skipton International. Skipton is a controller, responsible for the protection of the data it collects about you.

This Privacy Notice explains the types of personal data we collect, what we do with it, who we share it with, how long we keep it and your rights in relation to it.

It does not extend to other organisations such as external websites you may access from our website. Including those of other affiliates of the Skipton Building Society or any of its subsidiaries. Please read the privacy policy and terms & conditions of any other sites separately.

  • Personal data we collect

    General Personal Data

    The information that we collect about you may come from any of these sources:

    Data provided by you:

    • Application forms and related documents that you provide
    • Emails and letters
    • Telephone calls
    • Access of our website
    • Through using our services

    Data from third parties:

    • Publicly available, open-source information (e.g Companies House)
    • Government and Law Enforcement agencies
    • Credit Reference agencies (where applicable)
    • Fraud Prevention Agencies
    • Insurers
    • Companies that introduce you to us as a customer

    Sensitive (Special Category) Data

    The data protection regulations call certain types of sensitive “special category” data. These include data concerning:

    • Ethnic or racial origin;
    • Health;
    • Political opinions;
    • Religious or philosophical beliefs;
    • Trade union membership;
    • Sex life or sexual orientation; and
    • Genetics or biometrics

    In general we do not intentionally collect special category data relating to our customers but sometimes the personal data we collect may reveal this in specific and limited instances. If we make an adjustment to our service due to a health condition you inform us about, we will aim to record the adjustment without reference to the health condition unless it is necessary to also record this information to effectively make the adjustment and we have your consent.

    In any specific instances that we do collect and use special category data we will make sure at least one of the following applies:

    • We have your explicit consent;
    • It is required to by law;
    • There is a substantial public interest;
    • It is necessary to defend against actual or possible legal claims;
    • Where we believe you or someone else may be at risk; or
    • As otherwise permitted by data protection regulations.

    Where necessary for the purpose outlined in the Policy, we will also obtain, use, and share personal data about criminal convictions and other sensitive information including pending convictions, information about offenders, suspected offenders, allegations and investigations in the context of criminal activity, and information about bankruptcy/receivership, county court judgments, court records and pending orders.

    Additional Data Mortgages

    We use the data in the list below to understand your circumstances and needs, assess the suitability of the products and services you apply for or have with us, support financial crime and fraud prevention and meet regulatory requirements:

    • Property details and occupancy status,
    • Employment details including your salary, other income and status,
    • Additional financial details relating to other income, outgoings and spending habits,
    • Criminal convictions, pending convictions, bankruptcy/receivership, county court judgements, court records and pending orders.
    • Gender, to help locate your credit reference file. We do not use gender to inform lending decisions.
    • Other people who we collect, use and hold personal data about
    • Your authorised representative. This includes family members, attorneys, operators, mortgage guarantor, executors and beneficiaries to:
      • Manage our business relationship with them and to enable them to manage your accounts, products and services in line with your authorisation. Personal data may also be shared with the account holder about these authorised representatives (e.g. communications, transactions).

    We collect, use and hold personal data about the following people, in order to identify them and to manage our business relationship:

    • Brokers and financial advisers etc.
    • Solicitors, licensed conveyancers, and other professional advisors.
    • Voluntary and charitable organisations and their representatives/members
    • Field agents, debt collection agents, appointed receivers and trustees in bankruptcy.
    • Individuals cited as the source of funds for deposits into any products held with us.
  • Who we share data with and why

    There are times when we need to share your personal data and special category (sensitive) data with others. We will ensure that your data is shared securely.

    Processors

    ID-Pal

    We use a third-party provider ID-Pal to ensure the accuracy of user-provided information. You can find their privacy notice here: ID-Pal Privacy Policy.

    Feefo Review Site

    We may share customer personal details (name, email address and whether you are a mortgage or savings customer) with a third party review site in order to help us improve the service we provide to our customers. This site may contact you to request that you review your experience with Skipton. You can view their Privacy Policy here: Feefo Privacy Policy. You are under no obligation to complete a review if requested to do so.

    General Third Parties

    These are the types of organisations and individuals we share personal data with, and why.

    Joint account holders, including former, current and/or future account holders and trustees, your authorised representatives to manage:

     

    o   Enquiries, requests and further applications.

    o   Ongoing administration of your joint account, products and services.

    o   Processing transactions.

    Financial and mortgage advisors, where you have authorised them to act on your behalf.

     

    Credit reference agencies.

     

    o   To verify your identity and to help trace your whereabouts if we have been unable to contact you.

    o   To review and assess your suitability, and application for products and services.

    Field agents, debt collection agencies, tracing agents and appointed receivers and trustees in bankruptcy.

     

    o   Understand your circumstances and financial situation.

    o   Assist in recovering debt.

    o   Locate you when we have been unable to contact you via our usual communication channels.

    o   Meet legal requirements where receivers or trustees in bankruptcy have been appointed to deal with your financial affairs.

    Solicitors, licensed conveyancers, valuers, panel managers and other professional advisers.

    o   Provide professional services.

    o   Review and assess your suitability and application for products and services

    o   Manage your ongoing relationships

    o   Administer and manage disputes and/legal claims

    Fraud prevention agencies

     

    o   To enable us and other organisations to carry out checks for the purposes of preventing fraud and money laundering.

    o   Verify your identity.

    o   Assess your suitability for products and services.

    Other companies in the Skipton International Group:

     

    o   Manage relationships and experience with us and our group companies.

    o   Provide and improve our security and systems and protect you.

    o   Support any joint Group reporting requirements to our regulators.

    o   Financial crime and fraud prevention purposes.

    Financial Organisations

     

    o   Review and assess your suitability and application for products and services.

    o   Manage payments (Transactions in and out of your account).

    o   Financial crime and fraud prevention purposes.

    o   Assist with enquires and investigations.

    Law enforcement agencies including police forces and prosecuting authorities.

     
    • o   Assist with any ongoing investigations relating to the security and/or safety of individuals.
    • o   Financial crime and fraud prevention purposes.

    Courts and tribunals

     
    • Respond to court and tribunal requests
    • Manage and resolve complains, disputes and/or legal claims.

    Ombudsman and regulatory organisations
    • Provide our regulatory and governing bodies with data about our business.
    • Assist with enquiries, investigations, complaints and assessments.

    Mailing houses and printers

     
    • Provide you with service information, for example, account statements.
    • Provide you with a range of other communication about our products, services, news and offers.
    • Mailroom service for post.

    Third party systems, application support and cloud-based providers

     
    • Provide us with IT systems or applications.
    • Provide IT and application support, maintenance, fault resolution or system improvement.
  • What allows us to collect, use, share and keep your data

    We must have a lawful basis to collect, use, share and keep your personal data. The different lawful basis we use include:

    Legal obligation

     

    • At times we are required by law to collect, use, share or hold personal data.

    • As we operate in a regulated industry we have to comply with the laws and regulations set by government bodies and our regulators. Our regulators include the Guernsey Financial Services Commission, Jersey Financial Services Commission and The Office of the Data Protection Authority.

    Contract

     

    • This is where you choose to enter into an agreement with us or make an enquiry with the intention of entering into an agreement. It includes the collection, use and sharing of personal data necessary for the opening and ongoing administration of your accounts, products and services

    Legitimate interest

     

    • This is where it is necessary to collect, use, hold or share personal data to pursue a legitimate aim that does not unduly affect you or cause you undue detriment, damage or distress.

    • You have a right to challenge our legitimate interest, see the section on ‘Your Rights’ in this Notice for further details.

    Consent

     

    • This is where we ask for your consent to carry out certain activities such as marketing. You may withdraw your consent at any time.

    Explicit consent

     

    • This may be relied upon regarding sensitive (special category) data

    Vital interest

     

    • This is applied in very limited circumstances where we feel you or another individual may be at serious risk, for example, life or death circumstances and no other lawful basis can be applied.
  • How we use your personal data

    There are many reasons why we need your personal data. What personal data we need and how we use it will depend on a range of factors including the type of products and services you have with us, whether you have a sole or joint account, and many more.

    Managing your enquiry, application and ongoing account management

    We will collect, use, share and keep personal data needed for us to deal with your enquiry, process your application, provide any illustrations you require, and manage the ongoing administration of your accounts, products and services. This includes keeping your account records up to date and contacting you when needed.

    Decision in Principle and mortgage application

    We will collect, use, share and keep personal data, including relevant sensitive data, to provide you with a Decision in Principle if requested and to assess, review and process your mortgage application, and contact you when needed.

    When you request a Decision in Principle and/or apply for a mortgage, you will be taking the steps necessary to enter into a contract with us.

    This process involves reviewing your application with the use of financial models, with automated systems provided by Credit Reference Agencies and against our full lending criteria. This is to help us better understand your mortgage application and to assess the affordability of the products and services you apply for. When we do this the Credit Reference Agencies will keep a record of our search, whether or not you proceed with a full mortgage application. This is known as a credit footprint. A soft footprint is obtained at the Decision in Principle stage, with a hard footprint then obtained at full application stage. They do this so that you can see who has looked at your credit report, which should be when it was looked at and why. This record may also be seen by other lenders and could affect your ability to obtain future credit.

    All our mortgage applications are underwritten by a team here at Skipton.

    We will be unable to proceed with your mortgage application without undertaking one or more of these activities.

    Mortgages

    We will continue to assess the ongoing performance of your mortgage once you have taken it out.

    After the redemption of your mortgage, we will continue to use, share and hold your personal data for as long as required to meet our legal, regulatory or other lawful requirements and to deal with any potential claims or complaints.

    Guarantors

    Where a guarantor has been agreed on your mortgage account, we will share details of your account, including balance outstanding, interest rate(s) applicable, early repayment charges and monthly payments with them. The guarantor will also be advised of any additional borrowing or further application while they remain a guarantor.

    If you are appointed as a guarantor on a mortgage account, your data and payments made will be shared with the current and any future potential borrowers. This will include if one of them requests to add or remove a name from the account in the future.

    Debt recovery

    We have a legitimate interest to recover debt and to the extent necessary for this purpose we share data about you and how you conduct your account (including defaults, arrears and repossession hearings) with credit reference agencies, fraud prevention agencies, solicitors, debt collection agencies and/or tracing agents acting on our behalf to assist in recovering the debt and to locate you if we have been unable to contact you via our usual communication channels.

    Savings

    When you take out a savings product with us, the purposes for which we process your data include verifying your identity; opening your account; processing payments; calculating and applying interest.

    Tax reporting

    Your data will be used to meet our Foreign Account Tax Compliance Act (FATCA) reporting regulations where required.

    Identification, credit checking and crime prevention

    We process your personal data on the basis that it is necessary in the public interest for us to prevent fraud and money laundering, and to verify identity, in order to protect ourselves and to comply with laws that apply to us.

    More information about how we use this data is below.

    Credit and identity checks

    In order to process your application, we are required by law to identify you and assess the affordability of the products and services you apply for. We do this by using automated systems provided by one or more credit reference agencies. If you take products and services from us, we may also make periodic searches at credit reference agencies to manage your account in future.

    To verify customer identity and ongoing suitability we may conduct open-source searches to verify the information provided by customers.

    We will share your data with the credit reference agencies and they will give us data about you. This will include public data, for example, from the electoral register and other data, from your credit applications about your financial situation, financial history, shared credit and specific fraud prevention data.

    We will use this data to:

    • identify you.
    • assess your creditworthiness and whether you can afford to take the product.
    • prevent criminal activity, fraud and money laundering.
    • manage your accounts.
    • trace and recover debts.
    • ensure any offers provided to you are appropriate to your circumstances.

    We will continue to exchange data about you with credit reference agencies while you have a relationship with us. We will also inform the credit reference agencies about your settled accounts. If you borrow and do not repay in full and on time, credit reference agencies will record the outstanding debt. This data may be supplied to other organisations by credit reference agencies.

    The information we obtain from credit reference agencies is managed by them and limited to what is needed for our own purposes. We will tell you if your application is rejected because of information we have received from credit reference agencies. You will need to contact the credit reference agencies directly to request a full credit report if you require details of what they hold about you.

    Fraud prevention

    Before we provide services, goods or financing to you, we undertake checks for the purposes of preventing fraud and money laundering, and to verify your identity. These checks require us to process personal data about you.

    The personal data you have provided, we have collected from you, or we have received from third parties will be used to prevent fraud and money laundering, and to verify your identity.

    Details of the personal information that will be processed include, for example: name, address, date of birth.

    We and fraud prevention agencies may also enable law enforcement agencies to access and use your personal data to detect, investigate and prevent crime.

    We process your personal data on the basis that it is necessary in the public interest or for us to prevent fraud and money laundering, and to verify identity, in order to protect ourselves and to comply with laws that apply to us.

    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 six years.

    To support our legitimate interest and legal obligation to prevent fraud and money laundering, we may ask you about the source of any funds you deposit with us. If you are depositing funds given to you by another person we may ask for that person's details. We will keep a record of this information and provide it to law enforcement and fraud prevention organisations if necessary to support their investigations into alleged money laundering.

    Consequences of processing

    If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or to employ you, or we may stop providing existing services to you.

    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, financing or employment to you. If you have any questions about this, please contact the organisation that referred you to this page.

    Crime prevention and public safety

    Within our premises we have 24 hour CCTV in operation. Footage is reviewed by us, and where necessary passed to police or law enforcement agencies upon request following any incidents relating to the security and/or safety of individuals and to assist with any ongoing crime investigations. These processes support our legitimate interest to prevent crime and assist with public safety in our premises.

    Communicating with you

    We will use any of the contact details we hold for you to communicate with you about the products and services you hold with us, contact you as requested and to send you information we are required to provide you with by law or that is necessary for the provision of our services, for example, account statements.

    Marketing

    We may use your information to provide details about our products, services, news and offers that we believe may be of interest to you. The communications sent to you will be based on a range of factors including what products you already have with us.

    We will only get in touch with these types of communication if you have given your consent to be contacted for marketing purposes, and only contact you by the methods you have agreed to, for example, post, telephone, email or text.

    You can change your marketing preferences at any time by visiting a branch, calling us on 01481 730730. or email us at Optout@SkiptonInternational.com.

    Account Reviews

    We carry out reviews on all customers accounts to meet our regulatory requirements. This may involve contacting our customers for up to date information. E.g. passport, driving licence and proof of address.

    Quality assurance and communication monitoring

    We sometimes access your data as part of our internal quality assurance processes. We have a legitimate interest, to ensure that you have received the best and correct outcome for your situation. These monitoring activities also allow us to carry out ongoing training with our colleagues.

    We will record and monitor some of your contact with us, this includes telephone calls, emails, This is to help us in our continuous attempts to improve customer service and to offer additional protection and security. We also retain information for evidential purposes and to meet legal and regulatory requirements. Telephone calls may also be monitored for reasons of staff training.

  • Your rights

    You have certain rights in relation to your personal data, not all rights apply in all cases, and these are explained in more detail below:

    Be informed

    • We do this by providing this Privacy Notice and by giving information in our application forms, web pages and telephone conversations.

    Access your personal data/make a Subject Access Request:

    • We will provide a copy of the personal data we hold about you upon your request. We do not charge for providing the request provided your request is not manifestly unfounded, excessive or you make numerous requests in a short space of time

    Have inaccurate or incomplete personal data corrected:

    • We will correct and/or update your personal data if you inform us and we identify that it is inaccurate or incomplete.

    Request erasure

    • We will delete your personal data if:

      • We no longer need it for the reason(s) we informed you about.

      • You object (see next line) and we do not have an overriding valid business interest in retaining the same such as an outstanding debt.

    Object

    • You can object to the collection, use, sharing of your personal data where:

    • You do not agree to direct marketing (including profiling for direct marketing purposes).

    Portability

    • You can request a copy of the personal data you have provided in order for us to supply our services, to be sent to you and/or another service provider in a common electronic format.

    Restrict the collection, use, sharing and holding of personal data:

     

    • We will put on hold the use of your personal data when:

      • Its accuracy needs to be verified.

      • You have objected and we need to consider if our legitimate business interest overrides your request.

      • It has been collected, used, shared or kept unlawfully and you have requested that it's not deleted but want it to be restricted.

      • We no longer need it but you need it to establish, exercise or defend a legal claim.
    Challenging wholly automated decisions
    • We will inform you of any decisions that are wholly automated and are likely to have a legal or significant impact upon you. You have a right to contest and request a manual review of such decisions.
  • How long we keep your data – overview

    We have a Data Retention Policy in place which sets out how long personal data needs to be kept. When determining retention periods, we consider the following:

    • maximum or minimum retention periods identified by the law or regulatory guidance.
    • contractual rights and obligations.
    • customer expectations, the nature of your relationship with us and the types of accounts, products and services you have with us.
    • current or future operational requirements.
    • the risks involved in retention, deletion and removal.

    How long we keep your data by product, service or activity

    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. Where you have a mortgage with us, we will retain the details until the retention period has passed for both.

    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.

    Mortgage Account

     

    We will keep details of your mortgage account for 15 years after it has been paid off to meet our legal and regulatory obligations and to deal with your queries.

    Mortgage - Application only

     

    If you apply for a mortgage account, and we have carried out a credit search, but the application does not progress to opening, we will keep details of your application, including results of the credit search for 6 years to help us better understand your mortgage application, to assess the affordability of the products and services you applied for and deal with your queries. We will keep these details, whether or not you proceed with a full mortgage application.

    Back-up Systems

     

    After your personal data has been erased from our core banking systems, your data will be stored on our secure, restricted back-up systems for 7 years where your data will be encrypted.

    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.

    Marketing

     

    We will keep your details including your Marketing preferences and the methods you have chosen to be contacted by until you tell us otherwise. A history of the changes you make to your marketing preferences will be held in line with the retention periods for the relationships you have with us.

    Quality Assurance and communication monitoring

     

    When carrying out quality assurance checks to ensure you have received the best and correct outcome for your situation, we may keep a record of your name, account and/or unique reference number to evidence the check has been carried out and to meet our legal and regulatory obligations.

    Telephone recordings

     

    We will keep telephone and audio recordings for a minimum of 6 years, to meet our legal and regulatory obligations and deal with any queries

    CCTV

    We will keep CCTV Recordings from all our offices for 60 days.

    Tax Reporting

     

    We will keep details of any tax reporting we are legally required to report in line with the retention periods relevant to the relationship, accounts, products and services you have with us, to meet our legal and regulatory obligations.

    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 Channel Islands Financial Ombudsman (CIFO). 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 CIFO for a minimum of 6 years after the complaint has been resolved with CIFO or after a CIFO decision has been challenged to meet our legal and regulatory obligations.
  • Website

    The principle purpose of collecting personal data from you via this website is to assist in the efficient running of your accounts or to provide information or services specifically requested by you. When you complete our online enquiry forms, we ask for your contact details and other selected information, so that we can deal with your request as efficiently and effectively as possible. Our Cookie Policy can be found here.

    Our website also uses Google reCAPTCHA to help protect us from spam. CAPTCHA is a Turing test to tell human and bots apart. It is easy for humans to solve, but hard for “bots” and other malicious software to figure out. The reCAPTCHA privacy policy can be found here: https://policies.google.com/privacy/update?hl=en&safe=strict

  • Contact us

    If you have any concerns about how we collect, use, share or keep your personal data, or you think there has been a breach, you can contact us by going into branch, or by calling +44 (0)1481 730 730.

    If you require any more details about how we collect, use, share and store your personal data, or about your rights and how to exercise them, please contact:

    Data Protection Officer
    Skipton International

    PO Box 509

    Tudor House

    Le Bordage

    St Peter Port

    Guernsey

    GY1 6DS

    Tel: +44 (0)1481 730 730

    Email: Data.Protection@SkiptonInternational.com

     

    If you make a complaint, we will follow our internal complaints procedure to resolve your complaint quickly and fairly. If we cannot resolve your complaint to meet your expectations, you may contact:

    Channel Islands Financial Ombudsman

    PO Box 114

    Jersey

    Channel Islands

    JE4 9QG

    Guernsey: 01481 722218

    International: +44 1534 748610

    E-mail: enquiries@ci-fo.org

    Web: www.ci-fo.org  

    You also have a right to complain to The Office of the Data Protection Authority if you have any concerns about how we collect, use, share or keep your personal data by contacting them at:

    The Office of the Data Protection Authority (ODPA)

    Block A,

    Lefebvre Court

    Lefebvre Street

    St Peter Port

    GY1 2JP

    Telephone: +44 (0)1481 742 074

    Web: www.odpa.gg 

  • Changes to this Notice

    This notice was last reviewed and updated in August 2024.