Data Protection Notice

We may collect the following categories of personal data, including, without limitation:

• all personal data provided by you to us, such as:
  • name and contact details
  • nationality and national identity number(s)
  • identification documentation (including, for example, a copy of your passport)
  • tax status and tax identification number
  • employment history, income and source of wealth (for example properties that you own)
  • bank account details and/or account balance information including account activity and history
• information (such as those categories of personal data described above) received from another person, for example, if a person applies for a joint account with you, they may share your personal data with us or if you are a stakeholder in or manager of a business, and the business applies for products or services or enters into an agreement or interacts with us, we may obtain personal data about you to carry out checks against the business
• where permitted, information received from third parties acting on our behalf such as credit reference agencies, fraud prevention agencies and from other public sources (such as an electoral register)
• information about you that we may monitor and/or record from your telephone calls and electronic communications and electronic transactions
• information which we collect from you when you download our mobile app to access our services.

In limited cases, we may also collect “special categories” of data. Our money laundering, sanctions, financial crime and fraud prevention checks sometimes result in us obtaining information about actual or alleged criminal convictions and offences, as well as (for example) information relating to a person’s ethnicity, political opinions or religious beliefs. To the extent that we process such data, we will ensure that we have a lawful basis for processing. This may either be because we are required to comply with a legal obligation imposed by enactment or are otherwise authorised by law, in particular circumstances because the processing is justified as being in the public interest, or, in limited circumstances, because we have obtained your prior explicit consent. Where we have relied on your consent, you have a right to withdraw that consent at any time.

We will use your personal data for:

i. the provision of products and/or services requested by you

ii. managing your accounts

iii. making credit decisions (where applicable)

iv. detecting and preventing financial crime such as fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an ongoing basis (“Regulatory Assessments”)

v. statistical analysis, market research and assessment

vi. retaining your personal data processed as part of our Regulatory Assessments for future services entered into by you

vii. to monitor and record calls and electronic communications for:

a. investigating, preventing, detecting and prosecuting financial crime

b. enforcing and defending our and our affiliates’ rights, either ourselves, or through third parties

c. quality, business analysis, training and related purposes

viii. conducting direct marketing as described under heading ‘Marketing’ below

ix. otherwise as necessary to comply with applicable laws, regulations or codes of practice.

The provision of personal data by you may be necessary in order for us, and other third parties to which personal data are disclosed, to comply with our legal and regulatory obligations or for the performance of any contractual relationship with you or, for any other purposes, where it is in our legitimate interests to process such information (such as those described under paragraphs (i) (to the extent not covered by contractual obligation), (iii), (v), (vi), (vii)(c) and (viii) above).

We do not intend to make any decisions about you based on automated processing of personal data.

We may disclose certain personal data:

• to other affiliates in the Investec Group. Investec Group consists of Investec Bank plc (a company registered in the UK) and Investec Limited (a company registered in South Africa) and any of their direct or indirect subsidiaries and/or holding companies
• to our professional advisors, receivers and administrators (where applicable), and service providers (including, information technology systems providers)
• to courts, governmental and non-governmental regulators and ombudsmen
• to law enforcement agencies
• to relevant tax authorities
• to credit reference agencies who may use it to perform credit reporting and affordability checks for us and to verify your data, like identity (e.g. age and residence), and to prevent and detect criminal activity, fraud and money laundering
• to fraud prevention agencies, who will use it to prevent financial crime such as fraud and money-laundering and to verify your identity. If financial crime is detected, you could be refused certain services, finance or employment. Further details of how your information will be used by us and these fraud prevention agencies, and your data protection rights, can be viewed at: https://www.investec.com/en_gb/legal/UK/fraud-prevention-notice.html
• to any third party that acquires, or is interested in acquiring, all or part of our assets or shares, or that succeeds us in carrying on all or a part of its business, whether by merger, acquisition, reorganisation or otherwise
• as required or permitted by law
• to an introducer where you have been introduced to us (for example an independent financial adviser). We will inform the introducer of the outcome of the enquiry including whether we have agreed to provide you with the relevant product or service, (together, each of the bullet points above are referred to as “Recipients”).

We may transfer your personal data to the Recipients (including affiliates in the Investec Group) located in countries outside of the Bailiwick of guernsey, Jersey and the Isle of Man (each of whom are subject to an adequacy decision) or the EEA which may not have data privacy laws equivalent to those in the EEA. In those instances, we will take all necessary steps to protect your personal data in accordance with Applicable Data Protection Laws. For more information about how we transfer personal data, please contact our Data Protection Officer, whose details are described below under the heading ‘Enquiries, Requests or Concerns’.

Under Applicable Data Protection Laws, you may have a right (in certain circumstances):

• to request access to and rectification or erasure of your personal data
• to restrict or to object to the processing of your personal data
• to data portability (i.e. to request the transfer of personal data from one data controller to another in certain circumstances).

If you wish to exercise any of these rights you should contact our Data Protection Officer, whose details are described below under the heading ‘Enquiries, Requests or Concerns’.

You also have the right to lodge a complaint about the processing of your personal data with your local data protection authority if you consider that the processing of your personal data carried out by us or our affiliates, infringes Applicable Data Protection Laws.

The relevant data protection authorities in the Channel Islands and the Isle of Man are set out below:

The Office of the Data Protection Authority in Guernsey:
Web: https://www.odpa.gg

The Office of the Information Commissioner in Jersey:
Web: https://www.jerseyoic.org

The Information Commissioner in the Isle of Man:
Web: https://www.inforights.im/

We may contact you periodically to provide information regarding events, products, services and content that may be of interest to you and to invite you to participate in market research. If Applicable Data Protection Laws requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent.

If you wish to stop receiving marketing or market research communications from us, you can click on the unsubscribe link in the marketing communication or contact the Data Protection Officer as described below.

We will take steps to protect your personal data against loss or theft, as well as from unauthorised access, disclosure, copying, use or modification, regardless of the format in which it is held. Subject at all times to applicable laws, we will retain your personal data for a minimum period of 10 years from the end of our relationship with you.

We may revise or supplement our Data Protection Notice from time to time to reflect for example, any changes in our business, law, markets, and the introduction of any new technology. We will publish the updated Data Protection Notice on our website at https://www.investec.com/ibci-dataprotection and is available on request.

All enquiries, requests or concerns regarding this Notice or relating to the processing of personal data, should be sent to the Data Protection Officer at Investec Bank (Channel Islands) Limited, Glategny Court, Glategny Esplanade, St Peter Port, Guernsey, GY1 3LP, Channel Islands or by email to dataprotection@investec-ci.com

This Notice was last updated on 16 August 2023.