ABN AMRO and profiling

We have extensive knowledge and experience in fraud prevention. Unfortunately, we face increasingly sophisticated forms of fraud. We can take measures to prevent fraud as best we can, including the use of profiling. For security reasons, we cannot go into detail about the measures to be taken.

As a bank, we have to comply with the Wwft. This is the Money Laundering and Terrorist Financing (Prevention) Act. Therefore, we pay special attention to unusual transactions and those that by their ‘nature’ carry a higher risk of money laundering. For example, we look for transactions that deviate from your normal transaction pattern or transactions that have characteristics of money laundering or terrorist financing. If we suspect that a transaction is unusual within the meaning of the law, we must report it to the authorities. This investigation and possible reporting do not take place in a fully automated way. There is human intervention: specialised bank employees are closely involved. Again, we do not go into detail about how transactions are looked at. Criminals could take advantage of this.

To prevent overcrediting among customers and intervene more quickly when customers are in danger of getting into payment difficulties, we can use profiling. We then first make a list of the most common characteristics of customers who have encountered financial difficulties. These characteristics make up the profile. Then we look to see if there are customers who fit this profile. The regulator on duty of care and Customer Interest Central expects banks to continuously and actively monitor the financial situation of its customers to identify and prevent (potential) payment problems. We always check the use of your data against the requirements of privacy legislation.

How do we use profiling when you want to take out a product and during the term of your product? We explain this using an example. Suppose you have a credit with us:

1. To properly assess the risks for you and us, we make a risk analysis. We can do this when you want to take out a credit with us and during the term of your credit. We know from experience that certain characteristics are an indication of whether you can easily repay a credit. For example, whether you have a job or debts. We assess these characteristics in the risk analysis.
2. Customers who can normally repay a credit share some characteristics. And so do customers who cannot or run into problems during the term of the credit. Based on your characteristics, we create a risk profile. 
3. We compare your data with our existing profiles. Then we estimate the risk of whether you can repay the credit. We use further information besides the outcome of the risk analysis to assess whether we can grant you a credit.

We use profiling to support customers aged 18 and above in their financial wellbeing. For example, based on actual product data, such as a rejection for a personal loan and total account balance over a number of months, we can help customers understand more about financial wellbeing. We encourage the use of Insights functionality in the ABN AMRO app, offer a savings coach or budget coach to customers, give lectures at (high) schools and provide tips on the website.

We also use profiling for the purpose of our customer service. For example, we use customer segmentation so that we can inform you of relevant products and services from the bank. For example, we make customer selection based on a customer group that has taken out a mortgage. We inform this group of customers, for example, about making their house more sustainable and the options for taking out a loan for renovation. We can also select a customer group based on aggregated data such as total account balance over a number of months.

When we send you tips and offers, we try to find out where your interests lie based on a number of characteristics. For example, we will look at an age category and whether you already have other products with us. We will always first check whether you have objected to the use of personal data for marketing purposes and/or registered a right to object to receiving tips and offers.

We may go further to be even more relevant to you and meet your needs even better, if you give your prior consent. Think about offering specific products from our partners in the context of sustainable business or receiving specific energy saving tips based on your individual transaction data. You can withdraw your consent at any time.

Of course, we test the use of personal data against the privacy rules. You can always object to profiling for direct marketing purposes. If you do not have an agreement with us, we will check whether direct marketing is permitted in certain situations.

We may use automated decision-making when we enter into an agreement with you, e.g. to close a savings account online.

We may use automated decision-making without human intervention. This is permitted by law. These may include decisions that lead to not carrying out transactions because they may be fraudulent, for example in iDEAL transactions. These decisions can be made on the basis of a fully automated process without human intervention.

If we apply automated decision-making that has legal consequences for you or affects you significantly, we will clearly indicate this in advance. We will let you know what rights you have, for example the right of receiving an explanation of the automated decision, the right to let us know your point of view, the right to challenge this decision and the right to human intervention. Sometimes you will find more detailed information about the use of your personal information on our websites when you apply for a product or service. Suppose you want to apply for the Rood Staan (overdraft) product, you will find more information about the use of personal information on the page where you can digitally apply for the Rood Staan product.