What do we use your personal data for?

We use your personal data to help make our organisation and our services as effective, reliable and efficient as possible. This is done for the following six purposes:


To be able to enter into contracts with you and perform these contracts. If we do not have your personal data, we cannot offer you a current account or transfer money from or to your account for you, for example.


We study possible trends, problems, root causes of errors and risks, for instance to check whether new rules are properly complied with. This helps us prevent complaints and losses. It also allows us to intervene or issue a warning in time, for example if you are no longer able to repay your debts.

Better or new products and services

Do our products still meet your wishes and expectations? We carry out research in this area, using your personal data. We study trends and use personal data with the aim of analysing and continuing to develop our products and services.


You receive offers and news that is appropriate for you. That is why you receive as little advertising as possible for products you are probably not interested in or already have. In this context, we use personal data that we received from you, for instance because you requested information in the past or because you are already a client of ours. In this context, we may also use personal data that we received from other parties.

Security and the integrity of our bank and our sector

We are required to guarantee the security and integrity of the financial sector. We may therefore use your personal data to prevent or combat attempted or actual criminal or undesirable acts, such as fraud or terrorism. This enables us to guarantee the security and integrity of the financial sector, our organisation, our employees and you, as the client. We may also use your personal data for warning systems.

Social responsibility and legal obligations

As a bank, we play a key role in society. We help to prevent terrorist financing, money laundering and fraud, for instance by reporting unusual transactions or by identifying and stopping potentially fraudulent transactions and verifying transactions with you if necessary. Public authorities also ask us to provide personal data when they want to investigate problems or criminal offences. In that context, we check whether they have good reason to do so.

The banking sector is also one of the most regulated industries around. This means we have to comply with many rules. Besides European and Dutch rules, these rules also include the laws of other countries. We must therefore also record and keep personal data for this purpose, and sometimes also provide personal data to the competent authorities. We also check first whether this is permitted.

If you have not concluded a contract with us, we will not process your personal data in order to enter into and perform a contract with you. We may, however, use your personal data for other purposes, such as fraud detection. We always check first whether this is permitted.

Other purposes

We may use your personal data for other purposes than the purpose for which you supplies the personal data to us. In that case, the new purpose must be in line with the purpose for which you initially provided your personal data to us. The law refers to this principle as 'compatible use of personal data'. The law does not specify exactly when a use is compatible, although it does provide guidance.

  • Is this purpose clearly related to the purpose for which you initially provided the personal data? Is the new purpose appropriate to the initial purpose?
  • How did we originally receive the personal data? Did we obtain the personal data directly from you or in another way? 
  • What kind of personal data is concerned exactly? Is the personal data in question considered sensitive to a greater or lesser degree?
  • How would you be affected? Would you benefit, suffer or neither?
  • What can we do to ensure the highest possible level of protection for your personal data? Examples include anonymisation and encryption. 

Our group and your personal data

We may share your personal data within our group for specific purposes. We may do this for internal administrative purposes, to improve our services to you, because we are required to do so by law, or to fulfil our duty of care. If, for example, you apply to us for a loan, we need to know whether you have already obtained a loan from one of our subsidiaries. This allows us to gain a more complete picture of your financial situation. 

Subsidiaries are also allowed to contact you with offers. In that context, it must be possible for you to tell that the undertaking is affiliated with our group, for instance because our name or logos are used, or because this is clearly stated on the website or in advertising.

Required personal data

If we need personal data from you in order to conclude a contract with you, and you refuse to provide this data even though this is required by law, or these personal data are required for the contract, we will unfortunately not be able to enter into the contract with you. The required personal data is specified in the online forms and other forms we occasionally need you to complete.

Do you want us to remove your personal data from our systems? We are unfortunately unable to remove required or other personal data that we need, for instance for the performance of the contract you have with us, or because we are required to keep this data by law or owing to a legitimate interest of the bank.

Camera images, telephone calls, chat messages and video chat sessions

If you visit us, we may capture images of you on camera. We do this for security purposes. We can also be contacted by telephone, by chat messages or in video chat sessions, for instance for mortgage advice. We may also record your telephone calls, chat messages or video chat sessions with our advisers. We do this for the following purposes:

a) to improve our services, for example so that we can coach or assess the performance of our employees

b) owing to a legal obligation

c) in order to be able to provide evidence, or

d) to prevent fraud

We handle video and audio recordings with due care. They are subject to the same rules as other personal data. You may exercise your rights, such as your right of access.