Privacy notice

Welcome to the NatWest Housemate Privacy Notice. Your right to privacy and online security is important. This Privacy Statement describes how NatWest Housemate as part of the NatWest Group Plc and other authorised third parties will use the personal and financial information that is provided or collected in the NatWest Housemate app in order to facilitate the product.

1 Who we are

1.1 This privacy notice (the “Privacy Notice”) applies to all personal information processing activities carried out by National Westminster Bank Plc (NatWest).

1.2 NatWest is a data controller in respect of personal information that we process in connection with our business (including the products and services that we provide). In this notice, references to “we”, “us” or “our” are references to NatWest.

1.3 Our principal address is 250 Bishopsgate, London EC2M 4AA and our contact details can be located at www.natwest.com

1.4 We are a member of NatWest Group plc. More information about the NatWest group can be found at NatWestGroup.com by clicking on ‘Who We Are’.

1.5 We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with our business. “Personal information” means information about a living individual who can be identified from that information (either by itself or when it is combined with other information).

2 The purpose of processing

2.1 When you register to use the Housemate app, we will need to verify your identity. We may need to get in touch with you if we require further details. 

2.2 Within the Housemate app, we will collect, share and use your data for the purpose of providing you with shared ledger, aggregation, payment and rent recognition service (“the service”) as well as any linked products and services provided by the Bank. We will rely on your consent for the processing of your personal information in this capacity. If you wish to opt out at a later date, we will not be able to provide this product/service to you.

3 The information we collect

3.1 In order to confirm your identity and provide you with shared ledger, aggregation, payment and rent recognition service (“the service”) as well as any linked products and services provided by the Bank, we will collect and process the following information:

a)    your personal information, including name, email address, date of birth, mobile number, home address and country of residence

b)    your financial information, including your bank account details the transaction history of any of your NatWest Group accounts and non-NatWest Group bank accounts that you have chosen to be included within the service

c)    your home letting agent details, including their name and company number

d)    your landlord’s name

3.2 Information of any third parties contained within your transaction history.

3.3 Information you provide to us when using the service, including house name, house motto, expense descriptions, type, amounts, frequency and their comments and reminders, receipt images, notes and memos, in addition to any other information that you attach or share while using the service.

3.4 We may process your data and other information such as feedback, questions, comments, suggestions, or ideas, where we have a legitimate interest, to help us develop and improve the products and service we offer you.

3.5 Where permitted by law, we may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. It may involve investigating and gathering intelligence on suspected financial crimes, fraud and threats and sharing data between banks and with law enforcement and regulatory bodies.

4 How we share and collect data with third parties to run specific features on the Housemate App

4.1 Not only will we be able to work with you more closely to manage your existing tenancy, your track record as a tenant will enable Experian to use the information supplied to them to assist other landlords and organisations to:

a)    assess and manage any new tenancy agreements you may enter into.

b)    assess your financial standing to provide you with suitable products and services.

c)    manage any accounts that you may already hold, for example reviewing suitable products or adjusting your product in light of your current circumstances.

d)    contact you in relation to any accounts you may have and recovering debts that you may owe.

e)    verifying your identity, age and address, to help other organisations make decisions about the services they offer.

f)     help to prevent crime, fraud and money laundering.

g)    screen marketing offers to make sure they are appropriate to your circumstances.

h)    for Experian to undertake statistical analysis, analytics and profiling,

i)      and for Experian to conduct system and product testing and database processing activities, such as data loading, data matching and data linkage.

If you would like to see more information on these, and to understand how the credit reference agencies each use and share rental data as bureau data (including the legitimate interests each pursues) this information is provided in the Credit Reference Agency Information Notice (CRAIN) (for a paper copy, please get in touch with us or with Experian using the contact details Experian | The Sir John Peace Building | Experian Way | NG2 Business Park | Nottingham | NG2 1EP).

You are eligible for Rent Recognition with Experian only if your name is on the tenancy agreement and you pay rent to the person who owns the property directly or you pay an estate agent on their behalf. If you pay a housemate and they pay on your behalf or you pay in another way, like in cash, then sadly we cannot recognise these payments yet.

We need to see a pattern of payments for you to get the benefit, so we will wait until we see 6 consecutive months of consistent monthly or weekly payments before we report to Experian.  Once you have reached that mark then you will get the benefit for every payment. You are making a consistent payment if you pay the same rental amount per month or per week depending on your rent payment date, to the same payee. We will first try to identify consistent rent payments in the 180 days of historic transactions showing in the bank account(s) that you linked to Housemate.

In order for rent recognition to work, you must ensure the account you pay rent from remains linked to Housemate. Once we have seen 6 months of consistent monthly or weekly payments and reported them to Experian, if your tenancy changes in any way, you can update these details with us and we will update Experian regarding this so that your rental payments can continue to be recognised.

Rent Recognition will not directly improve your credit score but it can help lenders identify you if you apply for credit.

We will share a few key pieces of data with Experian, this includes data to identify you, name, date of birth, address and then the record that you have paid rent. We will continue to exchange information about you with Experian while you have a relationship with us. Experian will hold your rental data for the time limits explained in CRAIN (section 7). Rental data falls into the Identifiers (e.g. your name, address, date of birth) and financial account categories (i.e. tenancy account, rental payment information).

We and Experian will ensure that your information is treated in accordance with UK data protection law, so you can have peace of mind that it will be kept secure and confidential and your information will not be used for prospect marketing purposes.

If you would like advice on how to improve your credit history you can access independent and impartial advice from www.moneyadviceservice.org.uk (you can get a copy of your Statutory Credit Report by visiting www.experian.co.uk/consumer/statutory-report). 

If you are unhappy with anything relating to Rental Exchange, please contact us on the contact details above. You also have the ability to get in touch with the Information Commissioner’s Office. More information about this can be found using this link here: https://ico.org.uk/concerns/.

5 Sharing with third parties

5.1 We will not share your information with anyone outside NatWest Group except:

a)    where we have your permission.

b)    where required to provide you with the service.

c)    where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world.

d)    with credit reference and fraud prevention agencies.

e)    with third-party companies that provide you with services associated with your service.

f)     with third-party companies to analyse service usage, trouble shoot issues and behaviour analysis or other efforts to improve our service quality.

g)    if you have given us the permission to do so, with social media companies (in a secure format) so they assess build your profile when you register and set up the service.

h)    in anonymised form as part of statistics or other aggregated data shared with third parties; or

i)      where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above.

5.2 NatWest will not share your information with third parties for their own marketing purposes without your permission.

6 How we obtain information

6.1 In order to provide the service, we collect and hold information about you in the following ways:

a)    information you give to us to register as a user and use the service.

b)    information that we receive from third parties – including third parties who provide services to you or us, credit reference, fraud prevention or government agencies, and other banks (where permitted by law).

c)    information we already hold on your NatWest accounts transactions; and

d)    transaction information from other banks, that you have given us permission to receive.

7 Your rights

7.1 We want to make sure you are aware of your rights in relation to the personal information we process about you.

Your Rights	Rights Description
Access – You have a right to get access to the personal information we hold about you.	For more information on how to get access to your information and the documents we need you to submit, please visit our website at: supportcentre.natwest.com/Searchable/959249182/ How-do-I-submit-a- Subject-Access-Request-SAR.htm Or write to: NatWest, Subject Access Requests, Manchester Mailroom, 1 Hardman Boulevard, Manchester M3 3AQ.
Rectification – You have a right to rectification of inaccurate personal information and to update incomplete personal information.	If you believe that any of the information that we hold about you is inaccurate, you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal information. Please note that if you request us to restrict processing your information, we may have to suspend the operation of your account and/or the products and services we provide to you.
Erasure – You have a right to request that we delete your personal information.	You may request that we delete your personal information if you believe that: • we no longer need to process your information for the purposes for which it was provided; • we have requested your permission to process your personal information and you wish to withdraw your consent; or • we are not using your information in a lawful manner. Please note that if you request us to delete your information, we may have to suspend the operation of your account and/or the products and services we provide to you (see Section 9 below).
Restriction – You have a right to request us to restrict the processing of your personal information.	You may request that we delete your personal information if you believe that: • we no longer need to process your information for the purposes for which it was provided; • we have requested your permission to process your personal information and you wish to withdraw your consent; or • we are not using your information in a lawful manner. Please note that if you request us to delete your information, we may have to suspend the operation of your account and/or the products and services we provide to you.
Portability – You have a right to data portability	Where we have requested your permission to process your personal information or you have provided us with information for the purposes of entering into a contract with us, you have a right to receive the personal information you provided to us in a portable format. You may also request us to provide it directly to a third party, if technically feasible. We’re not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you.
Objection – You have a right to object to the processing of your personal information.	You have a right to object to us processing your personal information (and to request us to restrict processing) for the purposes described in Section 2 (above), unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests, or where we need to process your information to investigate and protect us or others from legal claims. Depending on the circumstances, we may need to restrict or cease processing your personal information altogether or, where requested, delete your information. Please note that if you object to us processing your information, we may have to suspend the operation of the product and services we provide to you.
Marketing – You have a right to object to direct marketing.	You have a right to object at any time to processing of your personal information for direct marketing purposes, including profiling you for the purposes of direct marketing (see Section 8 below).
Withdraw consent – You have a right to withdraw your consent.	Where we rely on your permission to process your personal information, you have a right to withdraw your consent at any time. We will always make it clear where we need your permission to undertake specific processing activities.
Lodge complaints – You have a right to lodge a complaint with the regulator.	If you wish to raise a complaint on how we have handled your personal information, you can contact our Data Protection Officer who will investigate the matter. We hope that we can address any concerns you may have, but you can always contact the Information Commissioner’s Office (ICO). For more information, visit ico.org.uk.

 

If you wish to exercise any of these rights, please contact us at housemate@natwest.com.

Please note that in some cases, if you do not agree to the way we process your information, it may not be possible for us to continue to provide the service to you.

8 Marketing Information

8.1 If you have permitted us to do so, then we will send you relevant marketing information (including details of other products or services provided by us or other NatWest Group companies which we believe may be of interest to you), by notification in the Housemate App, text message, email and telephone. If you change your mind about how you would like us to contact you or you no longer wish to receive this information, you can tell us at any time by changing your marketing preferences in the Housemate App.

9 How long we keep your information

9.1 By providing you with the shared ledger, aggregation, payment and rent recognition service, we create records that contain your information, such as customer account records and activity records. Records will be held in electronic format.

9.2 By providing you with the service, we will hold information on our database for a period of ten years after your relationship with the bank ends in order to defend or make legal claims.

9.3 We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that the bank will be able to produce records as evidence, if they’re needed.