NPP1 Personal or sensitive information, including facts or opinions, must be collected in a fair and lawful manner and be necessary for the business. Necessary here means information that will increase the efficiency and effectiveness of our business. This may extend to such things as interests or anniversaries only if we can show this information is necessary for the building of the customer relationship. There is information (known as NPP1.3 requirements) that you must provide to individuals when you collect their personal information. We do this by providing this information in 'Privacy statements' which are now included in all our application forms, both online and paper versions. There are occasions when personal information is collected outside of an application form so you must be aware of these requirements. |
NPP3 We must take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, up to date and complete. |
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... Collection of information
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There is a requirement to collect only the information that is necessary (NPP1) for the efficient conduct of the business, such as opening and administering a bank account. We may not collect information that is not necessary for our business purposes, even if the customer consents to this. The various VFS account application forms and prospectuses define the type of information required to set up that account. You are required to collect all necessary information and record it accurately (NPP3). For example, in assessing a loan application, you must ensure that you collect and verify all the information required to properly make the credit decision. We are required to disclose to customers:
These statements (as required under NPP1.3) are part of our application forms and prospectuses and require a customer's signature. |
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