Using Your Personal Information

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1 Important Using Your Personal Information A guide to help you understand how the personal information we hold about you may be used by Virgin Money and other organisations such as Credit Reference and Fraud Prevention Agencies.

2 Please read carefully 1) When you apply to us to open an account, we may: a) Check our own records for information on: Your identity; Your Account(s); If applying for a joint account, the records of any other applicants; and If you are an owner, director or partner in a business we may also check on your business accounts. b) Search credit reference agencies for information on: Your identity; And, if applying for credit: Your credit information; The credit information of any other applicants or those with which you already have a joint account or with anyone you have a financial link with; and If you are an owner, director or partner in a business, we may also check for credit information on your business. c) Search at fraud prevention agencies for information on you and any addresses at which you have lived and on your business (if you have one) and your business partners. d) Use credit scoring methods to assess the application and to verify your identity. e) If you are applying for a mortgage, we will make searches about you at the Council of Mortgage Lenders Possession Register. f) If you are borrowing money we may make enquiries we consider necessary in respect of the application including references from your employer, accountant, banker, lender, landlord, insurance broker, or solicitor. You will meet the costs for this. g) If applying for a mortgage, you authorise us or any appointed solicitor/conveyancer appointed by us to obtain account information (including repayment figures) from your lender. Where we have declined to lend you money using an automated decision making system, you have the right to have the application assessed manually where new or additional information is available. If we disclose information to a third party, as detailed above, this may include any previous or subsequent names. 2) What we do with the information supplied to us by Credit Reference Agencies and Fraud Prevention Agencies: a) Credit information and other information about you and those with whom you are financially linked which is provided by credit reference agencies and fraud prevention agencies may be used by us and other organisations if credit decisions are made about you or other persons you are financially linked with. b) This information may be used for other purposes including management of arrears, debt tracing, the prevention of money laundering as well as the management of your Account.

3 3) What we do with the information you supply to us: a) For lending applications, assess the application for credit and other related facilities. b) Verify your identity and the identity of any other applicants. c) Undertake checks for the prevention and detection of crime, fraud and/or money laundering. d) Information that is supplied to us may be sent to credit reference agencies. e) (i) If you are making a joint application, we may: Search, link and/or record information at credit reference agencies about all applicants; Link any individual identified as your financial associate, in our records; Take all parties information into account in future applications by either or both of you; and Continue this linking until the account closes, or is changed to a sole account and one of you notifies us that you are no longer linked. (ii) We will take into account information provided by credit reference agencies about persons with whom you are financially linked. f) If false or inaccurate information is provided and fraud is identified, details will be shared with fraud prevention agencies and this information may be accessed and used by law enforcement to prevent fraud and money laundering. Further details, explaining how the information held by fraud prevention agencies may be used, can be obtained by writing to the Data Protection Officer, Virgin Money plc, Freepost NT45, PO Box 2, Newcastle upon Tyne NE3 4BR. g) If you are applying for a mortgage, we may supply information provided in your application, or otherwise, to other parties such as: Your valuer; Your solicitor/conveyancer; Your intermediary; Your insurance company; Individuals waiving their rights of occupancy; Any company formally appointed by us to prepare or despatch mortgage or insurance related documents such as, mortgage illustrations, statements or other documents on our behalf, to any person having a legal right to this information; or If you want us to accept any other security for your loan, we may provide the person(s) giving the security (or legal adviser) with a copy of this application form and with any relevant information if they ask. h) We will treat your information as private and confidential (even where you are no longer a customer). Your data may, however, be disclosed in limited circumstances, when required by law, permitted under the Data Protection Act 1998: If there is a duty to the public to make this information known; If our interests mean we must give the information (e.g. to prevent fraud). However, we will not use this as a reason for giving information about you or your Accounts (including your name and address) to anyone else, including other companies for marketing purposes; If you ask us to make the information known; or We have your permission. or required by the Financial Services Compensation Scheme (and its verification solution provider). i) The information we collect and hold about you will not be kept any longer than is necessary. However, we are currently required by UK Money Laundering Regulations to maintain records for a period of 5 years from the end of the relationship and 6 years for tax purposes.

4 k) As per UK tax regulations we are required to provide details of interest earned to Her Majesty s Revenue and Customs. l) We may use your information for system testing and development, statistics, research and analysis. Where we do, we will apply the same level of care and protect the integrity of your information. m) If you are applying for a mortgage or already have one, information on any claim you make may be supplied to a data administration company so that it can be made available to other insurers. You also agree that, in response to any searches we may make in connection with this application or any claim, such data administration company may supply information it has received from other insurers about other claims you have made. 4) What we do when you have an account: a) We will manage your Account(s) with ourselves. This may involve using credit-scoring techniques. b) Where you borrow or may borrow from us, we will give details of your personal and/or business account (if you have one), including names and parties to the account and how you manage it/them to credit reference agencies. c) If you borrow and do not repay in full and on time, we may inform credit reference agencies. d) We may make periodic searches of our own records, credit reference agencies and fraud prevention agencies to manage your Account, including whether to make credit available or to continue or extend existing credit. e) If you have borrowed from us and do not make payments that you owe us, we will attempt to trace your whereabouts and recover debts. f) Undertake periodic statistical analysis or testing to ensure the accuracy of existing and future products and services. g) Where you have consented, Virgin Money and any other Group Companies may use your personal information for marketing purposes (including details of other companies products but we will not disclose your details to them) by post, fax, telephone, or other electronic means. Please advise us if you subsequently decide you no longer wish to receive such communications. h) If you are borrowing money and Virgin Money consider transferring or disposing the proposed loan, mortgage and other security you understand Virgin Money may disclose personal information (including information about your Account) and documents relating to you to any new party. i) Should any information be processed outside the European Economic Area, Virgin Money will ensure that country or territory will provide an adequate level of protection. j) For current account card holders, the transfer and disclosure of personal data may take place worldwide, including (but not exclusive to) Visa Europe and its employees. k) The transfer and disclosure of transaction data may take place worldwide.

5 l) Appropriate technical and organisational measures shall be taken against unauthorised or unlawful processing of your personal data and against accidental loss, damage or corruption. m) Telephone calls will be recorded for training and audit purposes. n) Under the Data Protection Act, we are required to follow rules of good practice for handling information (called the data protection principles). The Act also gives rights to individuals whose information is being collected and used. You are able to make a complaint to the Information Commissioner if you feel: You have been denied any of your rights, including your right to see the personal information an organisation holds about you; Personal information about you is used, held or disclosed: Unfairly; For a reason that is not the one it was collected for; or Without proper security. Personal information about you is: Inadequate, irrelevant or excessive; Inaccurate or out of date; or Kept for longer than is necessary. You can call the Information Commissioner s helpline on or for advice to help you to solve the problem or, in writing to: The Information Commissioner s Office, Casework and Advice Division, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. What Credit Reference and Fraud Prevention Agencies do 5) When we search your credit file and obtain personal information from credit reference agencies they will: a) Place a record of the search on your credit file whether or not an application proceeds. If the search was for a credit application the record of that search (but not the name of the organisation that carried it out) may be seen by other organisations when you (or your business) apply for credit in the future. b) Place an enquiry search on the personal credit files of any director/owner or partner that have been searched. These enquiry searches will not be seen by other organisations if any director/owner or partner applies for credit in the future. c) Link together the records of you and anyone that you have advised is your financial associate (including previous and subsequent names) or party to the account. Links between financial associates will remain on your and their files until such time as you or your partner successfully file for disassociation notice with the credit reference agencies. 6) They will supply to us: a) Credit information such as previous applications and the conduct of the accounts in your name and of your financial associate(s). b) Information to confirm your identity.

6 c) Public information such as county court judgements (CCJs) and bankruptcies. d) Electoral register information about you (and your business if applicable). e) Fraud prevention information. f) The information above may be summarised by credit reference agencies using credit scoring techniques. 7) When information is supplied by us, to them, on your Account(s): a) Credit reference agencies will record the details that are supplied on your personal and/or business account (including any previous and subsequent names) that have been used by the account holders and how you/they manage it/them. b) If you borrow and do not repay in full and on time, credit reference agencies will record this information. c) Records shared with credit reference agencies remain on file for 6 years after the account is closed/settled or from the date of default. 8) How your data will NOT be used by credit reference agencies: a) It will not be used to create a blacklist. b) It will not be used by the credit reference agency to make a decision. 9) How your data supplied to credit reference agencies may be used: a) The information which we and other organisations provide to the credit reference agencies about you and your financial associates may be supplied by credit reference agencies to other organisations and used by them to: Prevent crime, fraud and money laundering by, for example checking details provided on applications for credit and credit related or other facilities; Check the operation of credit and credit-related accounts; Verify your identity if you, your financial associates or business partners apply for other facilities; Make decisions on credit and credit related services about you, your partner, and other members of your household or your business. Manage your personal, your partner s and/or business (if you have one) credit or credit related account or other facilities; Trace your whereabouts and recover debts that you owe; or Undertake statistical analysis and system testing. 10) How your data supplied to fraud prevention agencies may be used: a) The information which we provide to the fraud prevention agencies about you and your financial associates may be supplied by fraud prevention agencies to other organisations and used by them to: i) Prevent crime, fraud and money laundering by, for example; Checking details provided on applications for credit and credit related or other facilities;

7 Managing credit and credit related accounts or facilities; Cross checking details provided on proposals and claims for all types of insurance; and Checking details on applications for jobs or when checked as part of employment. b) Verify your identity if you or your financial associate apply for other facilities including all types of insurance proposals and claims. c) Trace your whereabouts and recover debts that you owe. d) Conduct other checks to prevent or detect fraud. e) We and other organisations may access and use from other countries the information recorded by fraud prevention agencies. f) Carry out statistical analysis and system testing. How to find out more You can contact the credit reference agencies and fraud prevention agencies to establish what information is recorded about yourself. The information they hold may not be the same so it is worth contacting them all. They will charge you a small fee. The agencies we use are, CallCredit, Consumer Services Team, PO Box 491, Leeds LS3 1WZ or log on to Equifax PLC, Credit File Advice Centre, PO Box 3001, Bradford BD1 5US or log on to Experian, Consumer Help Service, PO Box 8000, Nottingham NG80 7WF or log on to Please contact us at Virgin Money plc, Freepost NT45, PO Box 2, Newcastle upon Tyne NE3 4BR if you want to receive details of the relevant fraud prevention agencies. If you obtain a copy of your credit file and believe it is inaccurate or incorrect, the credit reference or fraud prevention agency will be able to look into this for you. You can obtain (on payment of a fee) a copy of your personal information held by us, or details of the credit and fraud prevention agencies used by us, by writing to, The Data Protection Officer, Virgin Money plc, Freepost NT45, PO Box 2, Newcastle upon Tyne NE3 4BR. If you believe any information we hold to be incorrect, please let us know and we will be able to look into this for you. You have a right to have any inaccuracies deleted or corrected.

8 Alternative format If you require this in an alternative format such as braille, large print or audio, please call our Disability Awareness Team on Alternatively, our text phone number is or you can contact us at Frequently Asked Questions Q: What is a credit reference agency? A: Credit reference agencies collect and maintain information on consumers and businesses credit behaviour, on behalf of organisations in the UK. Q: What is a fraud prevention agency? A: Fraud Prevention Agencies collect, maintain and share, information on known and suspected fraudulent activity. Some credit reference agencies also act as fraud prevention agencies. Q: Why do you use them when I have applied to your organisation? A: Although you have applied to us and we will check our own records, we will also contact credit reference agencies to get information on your credit behaviour with other organisations. This will help us make the best possible assessment of your overall situation before we make a decision. Q: Where do they get the information? A: Information is available from: Publicly available information such as: The electoral register from local authorities; County court judgments from Registry Trust; and Bankruptcy (and other similar orders) from the Insolvency Service. Fraud information may also come from fraud prevention agencies. Credit information comes from information on applications to banks, building societies, credit card companies etc and also from the conduct of those accounts. Q: How will I know if my information is to be sent to a credit reference agency or fraud prevention agency? A: You will be told when you apply for an account if your application data is to be supplied. Q: Why is my data used in this way? A: We and other organisations want to make the best possible decisions we can, in order to make sure that you, or your business, will be able to repay us. Some organisations may also use the information to check your identity. In this way we can ensure that we all make responsible decisions. At the same time we also want to make decisions quickly and easily and, by using up to date information, provided electronically, we are able to make the most reliable and fair decisions possible.

9 Q: Who controls what such agencies are allowed to do with my data? A: All organisations that collect and process personal data are regulated by the Data Protection Act 1998 and are overseen by the Information Commissioner s Office. All credit reference agencies are in regular dialogue with the Commissioner. Use of the Electoral Register is controlled under the Representation of the People Act Q: Can just anyone look at my data held at credit reference agencies? A: No, access to your information is very strictly controlled and only those that are entitled to do so, may see it. Usually that will only be with your agreement or (very occasionally) if there is a legal requirement. Q: What is a financial link? A: Credit reference agencies may link together the records of people that are part of a financial unit. They may do this when people are known to be linked, such as being married or have jointly applied for credit or have joint accounts. They may also link people together if they, themselves, state that they are financially linked. Virgin Money plc Registered in England and Wales (Company No ). Registered Office Jubilee House, Gosforth, Newcastle upon Tyne NE3 4PL. Authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. VMP14V3 Valid from

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