What do we use your personal data for?

To enter into and perform agreements with you. For example, without your personal data we cannot offer you a current account, transfer money to or from your accounts for you or enter into a mortgage agreement with you. We also check during the term of your mortgage or credit agreement whether you can continue to meet your payment obligations. This allows us to intervene or warn you in time if we expect that you will no longer be able to repay your debts (on time).

We research trends and use personal data to analyse and further develop our products and services. We conduct research to check whether new and existing rules can be properly complied with. In this way, we can prevent complaints and damages. We also need to test whether systems (that enable us to provide our services to you or that we need to use to comply with the law) are working properly or investigate whether new technologies help us to better comply with the law, for example, or to serve you best.

We also do research on economic trends. Sometimes in collaboration with universities. This helps us better understand the economy. We do not share and/or publish research results or reports with other parties from which your personal data can be derived.

You will receive tips and offers that suit you and can benefit you as a customer. In doing so, we use personal data that we have received from you. For example, because you once requested information about sustainable products and services. Or because you are already a customer with us. We may also use personal data obtained from others. For example, from public data sources and from marketing agencies. Only if this is allowed by law.

We are obliged to safeguard the security and integrity of the financial sector. Therefore, we may use your personal data to combat or prevent (attempted) criminal or reprehensible behaviour. For example, in cases of fraud or terrorism. This allows us to safeguard our security and integrity, that of the financial sector, our employees and you as a customer. We may also use your data for our internal and external warning systems.

As a bank, we play an important role in society. Within the limits of the law, we take our own responsibility and may also participate in partnerships with public parties and with other (financial) institutions. From our specific social position, we want to contribute positively to certain social problems such as human rights violations, environment and climate. Examples include helping customers make their homes or businesses more sustainable and participating in joint ventures with other (financial) institutions in the field of combating terrorist financing or undermining crime and serious crimes. From our social position, we also want to contribute to our customers’ financial wellbeing within the limits of the law. We offer customers insight into money matters and provide budget coaching.

We help fight terrorist financing, money laundering and fraud. For example, by reporting unusual transactions or by recognising, stopping and, if necessary, verifying possible fraudulent transactions with you. (Foreign) government bodies also request data from us if they want to investigate problems or criminal offences. We then check whether there is a good reason for this.

The right to privacy protection is always central. We will always check whether use of personal data is permitted. Banks are one of the most regulated industries. This means we have to comply with many regulations. These are not only European or Dutch rules but also laws from other countries. This therefore also requires us to record, store and sometimes give personal data to authorised bodies. Here too, we always check first whether this is permitted. Have you not concluded an agreement with us? Then we do not process your personal data to conclude and execute an agreement with you. However, we may use your personal data for other purposes, such as fraud detection. We always check first whether the use for other purposes is permitted. 

The right to privacy protection is always top of mind. We will always test whether use of personal data is allowed. Banks are one of the most regulated industries. This means we have to comply with many rules. These are not only European or Dutch rules but also laws from other countries. This therefore also requires us to record, store and sometimes give personal data to authorised bodies. Again, we always check first whether this is permitted.

We may use your personal data for purposes other than those for which you have given us the personal data. The new purpose must then fit in with the purpose for which you initially gave us your personal data. This is called ‘compatible use of data’ in the law. The law does not say exactly when this is the case, but does provide pointers:

• Is there a clear connection to the purpose for which you previously gave the personal data? Does the new purpose fits within the original purpose?
• How did we ever receive the personal data? Did we receive the personal data from you or by some other means?
• Exactly what kind of personal data is involved? Are they sensitive or less sensitive?
• What are the consequences for you? Is it to your advantage, disadvantage or does it not matter?
• What can we do to best protect your personal data? Consider anonymising, masking or encrypting your personal data. 

We may share your personal data within our group for certain purposes. This may be for internal administrative purposes such as optimising data quality and to improve our service to you, as required by law. Or to better and more efficiently comply with the law or to fulfil our duty of care. We give some examples:

• We aim to provide you as a customer with added value in our services if you bank with us for both business and private purposes. If you have a checking account with ABN AMRO, we can also offer you a business loan. We are happy to offer you access to a full range of products and services that best meet your needs and wishes. Only if allowed by law.
• Under the banking oath and legal obligations, we always weigh your customer interests in our decisions. For example, if you apply for a loan with us or one of our subsidiaries, it is necessary to know whether you already have a loan, current account or savings with us or one of our group companies and whether you meet your obligations. If you are not meeting your obligations, it is necessary to know what other products you have with us or a subsidiary and whether you can meet these obligations. This allows us to get a more complete picture of your financial situation for your own financial wellbeing and our group’s risk management. In order as a group, to better comply with the rules against money laundering and terrorist financing This may mean, for example, that in case we have detected certain illegal activities on your bank account at ABN AMRO, we share this information with our subsidiaries if you are also a customer there.
• Personal data may also need to be shared within our group in fraud investigations. ABN AMRO uses central IT systems that allow sharing of relevant personal data between parent and subsidiary companies only for justified purposes. To this end, we have taken appropriate technical and organisational measures to ensure that the sharing of personal data is secure and shared only for those specific purposes so as to prevent any unlawful use of your personal data. For example, ABN AMRO and its group companies may share personal data in this way in order to respond to regulatory requests adequately and within a specific timeframe, always in compliance with privacy laws and any applicable local laws and regulations.

If you have a payment account with us and you want to take out insurance with ABN AMRO Verzekeringen (joint venture ABN AMRO and NN Group), as an intermediary we will share the data you provide with ABN AMRO Verzekeringen in order to be able to take out the insurance and to fulfil our legal obligations. The privacy policy of ABN AMRO Verzekeringen applies if you have taken out insurance with ABN AMRO Verzekeringen. The same applies to other insurers if ABN AMRO acts as intermediary.

Do we need personal data from you to conclude an agreement with you? And do you not want to provide them even though the law states that you must? Or are these personal data necessary for the agreement? Then, unfortunately, we cannot enter into an agreement with you. In the (online) forms you sometimes have to fill in, you can see which personal details are required and we explain how to use specific data.

Do you want us to delete your personal data from our systems? Unfortunately, this is not possible for mandatory or other personal data we need. For example, for the performance of the agreement you have with us. Or because we are obliged to keep your data by law. The bank may also have a legitimate interest to keep your personal data.

If you visit a bank branch, we may make camera recordings of you. This is necessary to prevent burglary, theft and vandalism and for the safety of our customers and employees. It is also possible to contact us by phone, video banking and chat, for example for mortgage advice. We may make recordings of these conversations. We do this in order to:

• improve our services, for example to support our employees with new techniques, e.g. the automated summarisation and recording of telephone calls from our customer service,
• coach and assess employees;
• because of a legal obligation;
• to provide evidence, or;
• to prevent fraud.

Recording falls under the same rules as other personal data. You can exercise your rights, such as the right to access.