- Who we are
- The information we process and how we obtain information
- Your rights
- Changes to the way we use your information
- How we use and share your information with other NatWest Group companies
- Sharing with third parties
- Transferring information overseas
- Communications with you
- How long we keep your information
- Schedule A – Schedule of Purposes of Processing
1.1 This privacy notice (the “Privacy Notice”) applies to all personal information processing activities carried out by NatWest Group plc (NatWest).
1.2 Royal Bank of Scotland is a data controller in respect of personal information that we process in connection with our business (including the products and services that we provide). In this notice, references to “we”, “us” or “our” are references to Royal Bank of Scotland.
1.3 Our principal address is 36 St Andrew Square, Edinburgh EH2 2YB and our contact details can be located at rbs.co.uk
1.4 We are a member of NatWest Group plc (“NatWest Group”). More information about the NatWest Group can be found at natwestgroup.com.
1.5. We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with our business. “Personal information” means information about a living individual who can be identified from that information (either by itself or when it is combined with other information). We may update our Privacy Notice from time to time. When we do we will communicate any changes to you and publish the updated Privacy Notice on our website. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.
Your information is made up of all the personal information we hold about you. It includes:
2.1 information you give us – you may give us information by filling in the registration page on our site or by corresponding with us by phone, email or otherwise. The information you give us may include your name, address, email address and phone number;
2.2 information that we learn about you through our relationship with you;
2.3 information we gather from the technology which you use to access our services, for example a) location data from your mobile phone, an Internet Protocol (IP) Address used to connect your device to the internet, your login information, browser type and version, operating system and platform; and
b) Full Uniform Resource Locators (URL) clickstream to, through and from our site, items viewed or searched for on our site, page response times, length of visit or page interaction information.
3.1 We want to make sure you are aware of your rights in relation to the personal information we process about you. We have described those rights and the circumstances in which they apply below. If you wish to exercise any of these rights, if you have any queries about how we use your personal information that are not answered here, or if you wish to complain to our Data Protection Officer, please contact us at 03457 24 24 24. Overseas number: +44 131 549 8888. Minicom: 0800 404 6160.
3.2 Please note that in some cases, if you do not agree to the way we process your information, it may not be possible for us to continue to let you take part in MoneySense and/or provide certain services to you
Rights & descriptions
Access – You have a right to get access to the personal information we hold about you. If you would like a copy of the personal information we hold about you, please write to: RBS, Subject Access Requests, Manchester Mailroom, 1 Hardman Boulevard, Manchester M3 3AQ. Or contact us at 03457 24 24 24. Overseas number: +44 131 549 8888. Minicom: 0800 404 6160. For more information on how to get access to your information and the documents we need you to submit, please visit our website at: https://www.supportcentre-rbs.co.uk/Searchable/1022957922/How-do-I-submit-a-Subject-Access-Request-SAR.htm
Rectification – You have a right to rectification of inaccurate personal information and to update incomplete personal information. If you believe that any of the information that we hold about you is inaccurate, you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal information. Please note that if you request us to restrict processing your information, we may have to suspend MoneySense and/or provide certain services to you.
Erasure – You have a right to request that we delete your personal information. You may request that we delete your personal information if you believe that:
- we no longer need to process your information for the purposes for which it was provided;
- we have requested your permission to process your personal information and you wish to withdraw your consent; or
- we are not using your information in a lawful manner.
Please note that if you request us to delete your information, we may have to suspend MoneySense and/or provide certain services to you.
Restriction – You have a right to request us to restrict the processing of your personal information. You may request us to restrict processing your personal information if you believe that:
- any of the information that we hold about you is inaccurate;
- we no longer need to process your information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or
- we are not using your information in a lawful manner.
Please note that if you request us to restrict processing your information, we may have to suspend MoneySense and/or provide certain services to you.
Objection – You have a right to object to the processing of your personal information. You have a right to object to us processing your personal information (and to request us to restrict processing) for the purposes described in Schedule A – Purposes of Processing (below), unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests or where we need to process your information to investigate and protect us or others from legal claims. Depending on the circumstances, we may need to restrict or cease processing your personal information altogether, or, where requested, delete your information. Please note that if you object to us processing your information, we may have to suspend to let you take part in MoneySense and/or provide certain services to you.
Withdraw consent – You have a right to withdraw your consent. Where we rely on your permission to process your personal information, you have a right to withdraw your consent at any time. We will always make it clear where we need your permission to undertake specific processing activities.
Lodge complaints – You have a right to lodge a complaint with the regulator. If you wish to raise a complaint on how we have handled your personal information, you can contact our Data Protection Officer who will investigate the matter. We hope that we can address any concerns you may have, but you can always contact the Information Commissioner’s Office (ICO). For more information, visit ico.org.uk.
4. Changes to the way we use your information
From time to time we may change the way we use your information. Where we believe you may not reasonably expect such a change we will notify you and will allow a period of at least 30 days for you to raise any objections before the change is made. However, please note that in some cases, if you do not agree to such changes it may not be possible for us to continue to let you take part in MoneySense and/or provide certain services to you.
We will only use and share your information where it is necessary for us to lawfully carry out our business activities. Your information may be shared with and processed by other NatWest Group companies. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail in Schedule A – Purposes of Processing.
We will not share your information with anyone outside NatWest Group except:
6.1 where we have your permission;
6.2 where required for your engagement with and involvement in the MoneySense programme;
6.3 where we are required by law and to law enforcement agencies or government entities;
6.4 where required for a sale, reorganisation, transfer or other transaction relating to our business;
6.5 in anonymised form as part of statistics or other aggregated data shared with third parties; or
6.6 where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above.
We will only share your information with third parties on a limited basis following due diligence and in accordance with our internal procedures.
NatWest Group will not share your information with third parties for their own marketing purposes.
7.1 We may transfer your information to organisations in other countries (including to other NatWest Group companies) on the basis that anyone to whom we pass it protects it in the same way we would and in accordance with applicable laws.
7.2 In the event that we transfer information to countries outside of the European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway), we will only do so where:
a) the European Commission has decided that the country or the organisation we are sharing your information with will protect your information adequately;
b) the transfer has been authorised by the relevant data protection authority; and/or
c) we have entered into a contract with the organisation with which we are sharing your information (on terms approved by the European Commission) to ensure your information is adequately protected. If you wish to obtain a copy of the relevant data protection clauses, please contact us at 03457 24 24 24. Overseas number: +44 131 549 8888. Minicom: 0800 404 6160.
8.1 We will contact you with information relevant to the MoneySense programme (including updated information about how we process your personal information), by a variety of means including via email, text message, post and/or telephone. If at any point in the future you change your contact details you should tell us promptly about those changes.
If you change your mind about how you would like us to contact you or you no longer wish to receive this information, you can tell us at any time by contacting us at MoneySense@nationalschoolspartnership.com
8.2 We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes outlined in Schedule A – Purposes of Processing.
9.1 By taking part in the MoneySense programme, we create records that contain your information. Records can be held on a variety of media (physical or electronic) and formats.
9.2 We manage our records to help us to serve our customers well (for example for operational reasons, such as dealing with any queries relating to MoneySense) and to comply with legal and regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities.
9.3 Retention periods for records are determined based on the type of record, the nature of the activity, product or service, the country in which the relevant NatWest Group company is located and the applicable local legal or regulatory requirements. We (and other NatWest Group companies) normally keep customer account records for up to six years after your relationship with the bank ends, whilst other records are retained for shorter periods, for example 90 days for CCTV records or 12 months for call recordings. The retention period for MoneySense is six years. Retention periods may be changed from time to time based on business or legal and regulatory requirements.
9.4 We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that the bank will be able to produce records as evidence, if they’re needed.
9.5 If you would like more information about how long we keep your information, please contact us at 03457 24 24 24. Overseas number: +44 131 549 8888. Minicom: 0800 404 6160.
We are committed to ensuring that your information is secure with us and with the third parties who act on our behalf. For more information about the steps we are taking to protect your information please visit personal.rbs.co.uk/personal/security-centre.html or contact us at 03457 24 24 24. Overseas number: +44 131 549 8888. Minicom: 0800 404 6160.
We will only use and share your information where it is necessary for us to carry out our lawful business activities. Your information may be shared with and processed by other NatWest Group companies. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail below:
We may process your information where it is necessary to enter into a contract with you to provide MoneySense services. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue with MoneySense. This may include processing to:
- provide access to the MoneySense programme website(s) and allow you to participate in the interactive features of the website(s);
- allow access to the MoneySense programme resources;
- provide you with information on MoneySense workshop opportunities;
- create contact between schools and volunteers (and between volunteers themselves) for workshop planning etc.
We may process your information where it is in our legitimate interests do so as an organisation and without prejudicing your interests or fundamental rights and freedoms. This may include processing your information to:
- develop, test, monitor and review the performance of services, internal systems and security arrangements offered by NatWest Group companies;
- assess the quality of our service to customers and to provide staff training;
- improve the relevance of offers of products and services by NatWest Group companies to our customers;
- comply with legal and regulatory obligations.
We may process your information in the day-to-day running of MoneySense. This may include processing your information to:
- provide you with information on the MoneySense programme in general (e.g. newsletters);
- issue surveys to assist with MoneySense workshop evaluation and programme improvements;
- tell you about additional volunteering possibilities such as providing support at events; or
- let you know about opportunities to take part in bank-wide PR activities such as MoneySense adverts/online videos.