1. Not providing your personal information
If you do not give us your Personal Information, we may not be able to provide products and services to you.
2. Kinds of personal information we collect and hold
Personal Information is information that can identify you.
The nature of personal information collected and maintained by us generally comprises name, address, date of birth, contact details including landline and mobile telephone numbers and email address, residency status, the name and contact details of your professional advisers or representatives such as your solicitor, accountant, financial planner etc, financial information and details contained in identity documents provided to us such as government identifiers in your passport, drivers licence number.
3. Collecting your personal information
We must obtain and collect personal information from you so we can provide products and services to you, provide information and marketing material to you and satisfy certain legislative and regulatory requirements. We may collect personal information about you when you apply to us for a product or service we offer, open an account or register for access to our services or when you deal with us via telephone, fax, email, other electronic methods, or send us a letter. In order to identify you and comply with legislation. Where you deal with us via an agent or attorney we will also collect the personal information of the agent or attorney when or before we deal with such person(s). We may also receive your updated personal information from third parties where we are trying to locate you.
For training and compliance purposes we record and randomly monitor telephone calls to our customer service officers. If you request information from us (e.g. by using our website or call centre), we may collect your contact details, including your name, postal and email addresses and your telephone numbers.
4. Using and disclosing your personal information
We will only collect, hold, use or disclose personal information we collect as permitted by the WBP. Personal information is collected and held in different ways including within our computerized systems such as computer hard drives, email programs and electronic servers, within our data centre’s, physically stored onsite and in external storage facilities.
The personal information collected by us is used for the purposes of assessing an application, establishing, administering, operating and maintaining your client relationship with us.
We may also disclose your personal information to external parties, including but not limited to:
- Any third party or organisation that introduces you to us or other financial institutions linked with your dealings with us
- Any third party or organisation we introduce you to and provide information for the operation and management of your affairs
- Third parties which are your representatives including your legal advisers, accountants and financial advisers
- Third parties involved in maintaining, reviewing and developing our business systems, procedures and infrastructure including for the purposes of system audit and testing or upgrading our computer system
- Verification of your identity and to detect fraud, money laundering or terrorist financing activities under the Anti-Money Laundering Act
- Taking any action we consider appropriate to meet our compliance obligations
- As required by law
- As authorised by law
We will use our best endeavours to ensure that each of our representatives and the businesses that we deal with adhere to the WBP Principles. If you have any concerns about this, contact us.
5. Protecting your personal information
We take reasonable steps to protect your Personal Information from misuse, loss, unauthorised access, modification and disclosure. These include security of our premises, restricting access to personal information to employees who need to perform their day to day employment tasks, providing employee training in relation to privacy and confidentiality, data encryption technology, firewalls, passwords and identifiers to prevent unauthorised access.
6. Accessing your personal information
You may request access to your Personal Information. Access to your Personal Information is not the same as access to a file that we maintain as part of our business processes, nor does it necessarily include all information that we may have collated in relation to you.
We will normally grant you access to your Personal Information within 30 days of receiving your written request subject to us receiving written evidence of your identity. In some complex cases this may take longer and we will advise you of this.
9. Privacy complaints
We will use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response, you can contact the Autoriteit Persoonsgegevens by visiting their website at www.autoriteitpersoonsgegevens.nl.
10. Contact details
If you would like further information regarding this policy, please contact us.