First Direct - HSBC Memory

funkycredit

That makes more sense in my case. Different address, phone, employer, salary etc etc etc 

Although you'd think they'd have checked my existing HSBC account (opened fine this year). 

Oh well. 😂

eskbanker

funkycredit said:

So it appears that FD go back 20+ years, in relation to their memory of keeping data. 

I closed my FD account before y2k and it was all paid / all good etc and just moved banks through choice. 

Now, when I apply I'm met with this email which pretty much tells me it's internal records they're relying on - not the CRA info. 

Oh well - least we know their memory is longer than most. 

I'm not overly bothered, just slightly curious what info they think they have so SAR will be sent today me thinks. With a clear instruction to cease processing my data. After 20 years there's no legal (or otherwise) reason for my data to be there. 

Anyway - thought I'd share as I've seen a few posts about HSBC / FD in this regard! 

I'm not following the logic of your conclusion that they're relying on internal records - they're saying in that screenshot that they're rejecting your application because you didn't meet their account opening criteria, so it's plausible that they've made the decision based solely on data you supplied within the application, rather than taking into account anything historical (or current data elsewhere within HSBC or CRAs, despite the boilerplate text included as standard)?  Is there anything specific that leads you to believe that the rejection is due to being a previous customer?

colsten

funkycredit said:

colsten said:

stclair said:

I would challenge that surly they shouldn't be keeping information that long. It might also be worth be worth speaking to the ico about the matter.

There is no maximum time limit. Any company can keep records for as long as they have a business need for it. It appears that FD/HSBC deem it necessary for their business to know whether anyone ever had an account with them. You may disagree with this, but it is their business and they can decide what their business needs are. 

https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/principles/storage-limitation/

Within reason. As I've just said, 20 years later when there were no defaults / negative elements does not come under any lawful business need for retention. It's their business, agreed. But it's my data. 

Anyway, wasn't trying to discuss the rights and wrongs of it. Was just highlighting that they do keep historic data and they rely on it heavier than any automated decision; clearly! 

They may have decided 20 years ago that they never want you as a customer again. If this sort of stark decision is part of their acquisition strategy, they have a business need to keep your data indefinitely, or at least until your reasonable life expectancy has been reached or exceeded by x years.

Then again, the rejection of your application might have had totally different reasons. Perhaps you just don't fit the customer profile they are seeking to acquire.

Whatever their reason, they can decide whether they take you on as a customer or not. The only legal obligation banks have is that one of them must give you a Basic account if none of them is willing to give you a 'normal' account.

funkycredit

eskbanker said:

funkycredit said:

So it appears that FD go back 20+ years, in relation to their memory of keeping data. 

I closed my FD account before y2k and it was all paid / all good etc and just moved banks through choice. 

Now, when I apply I'm met with this email which pretty much tells me it's internal records they're relying on - not the CRA info. 

Oh well - least we know their memory is longer than most. 

I'm not overly bothered, just slightly curious what info they think they have so SAR will be sent today me thinks. With a clear instruction to cease processing my data. After 20 years there's no legal (or otherwise) reason for my data to be there. 

Anyway - thought I'd share as I've seen a few posts about HSBC / FD in this regard! 

I'm not following the logic of your conclusion that they're relying on internal records - they're saying in that screenshot that they're rejecting your application because you didn't meet their account opening criteria, so it's plausible that they've made the decision based solely on data you supplied within the application, rather than taking into account anything historical (or current data elsewhere within HSBC or CRAs, despite the boilerplate text included as standard)?  Is there anything specific that leads you to believe that the rejection is due to being a previous customer?

Yea - I'm reading it as any intelligent person would, with known knowledge of having to give a base reason for rejections. They've clearly stated they check their own records and those of a third party (CRA's etc). My credit files are fine. No fraud warnings etc. 

So where they say "Where applicable we also review how you manage any accounts you have with other HSBC Group companies and information provided by a Credit Reference Agency." - followed by "Your application was not declined due to information held by Credit Reference Agencies.  " - one can safely deduce it was other hsbc data. 

funkycredit

colsten said:

funkycredit said:

colsten said:

stclair said:

I would challenge that surly they shouldn't be keeping information that long. It might also be worth be worth speaking to the ico about the matter.

There is no maximum time limit. Any company can keep records for as long as they have a business need for it. It appears that FD/HSBC deem it necessary for their business to know whether anyone ever had an account with them. You may disagree with this, but it is their business and they can decide what their business needs are. 

https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/principles/storage-limitation/

Within reason. As I've just said, 20 years later when there were no defaults / negative elements does not come under any lawful business need for retention. It's their business, agreed. But it's my data. 

Anyway, wasn't trying to discuss the rights and wrongs of it. Was just highlighting that they do keep historic data and they rely on it heavier than any automated decision; clearly! 

They may have decided 20 years ago that they never want you as a customer again. If this sort of stark decision is part of their acquisition strategy, they have a business need to keep your data indefinitely, or at least until your reasonable life expectancy has been reached or exceeded by x years.

Then again, the rejection of your application might have had totally different reasons. Perhaps you just don't fit the customer profile they are seeking to acquire.

Whatever their reason, they can decide whether they take you on as a customer or not. The only legal obligation banks have is that one of them must give you a Basic account if none of them is willing to give you a 'normal' account.

Fair enough. I don't even need an account. I'll just write this off and forget HSBC. 🍻

eskbanker

funkycredit said:

Yea - I'm reading it as any intelligent person would, with known knowledge of having to give a base reason for rejections. They've clearly stated they check their own records and those of a third party (CRA's etc). My credit files are fine. No fraud warnings etc. 

So where they say "Where applicable we also review how you manage any accounts you have with other HSBC Group companies and information provided by a Credit Reference Agency." - followed by "Your application was not declined due to information held by Credit Reference Agencies.  " - one can safely deduce it was other hsbc data. 

With your intelligence you should be able to understand that they say that (as well as reviewing the application itself) where applicable they check internal data and CRAs, and that your application wasn't declined because of CRA data.  You're obviously free to jump to your own conclusions, but they're not directly supported by the evidence here, so you're adding two and two and making five.  In any case, you've since said that you have an HSBC account, so even if they were looking at internal data, there's nothing I can see that suggests that your previous FD account was a factor rather than the current HSBC one?

funkycredit

Not at all. They wouldn't have mentioned about their own data AND credit reference data if it wasn't pertinent. It's a bit like you ordering a bike and having an invoice with a bike plus the things you DIDN'T take (ie wider wheels, tyres etc). They'd only mention relevant info, not random unrelated info. 

Therefore I'm not adding anything up. I'm reading it as it's intended to be read - they've used their own data from +20 years ago and declined based on that. 

There's absolutely no disputing that. 

eskbanker

funkycredit said:

Not at all. They wouldn't have mentioned about their own data AND credit reference data if it wasn't pertinent. It's a bit like you ordering a bike and having an invoice with a bike plus the things you DIDN'T take (ie wider wheels, tyres etc). They'd only mention relevant info, not random unrelated info.

The format of those messages is likely to be heavily standardised, but they obviously will review the data on the application itself and may (where applicable) use additional data from two other sources (internal and CRA).  You've apparently decided that because they say it's not the CRA data then that means it must be internal data, rather than the data on the application itself.

funkycredit said:

Therefore I'm not adding anything up. I'm reading it as it's intended to be read - they've used their own data from +20 years ago and declined based on that.

You've failed to address the fact that their internal group data will definitely include your existing HSBC account but might include old FD info from over twenty years ago, and have concluded that (even if internal data is the cause) the only possible cause for the decline must be the latter.

funkycredit said:

There's absolutely no disputing that. 

Er, yes there is!  See above....

born_again

funkycredit said:

Not at all. They wouldn't have mentioned about their own data AND credit reference data if it wasn't pertinent. It's a bit like you ordering a bike and having an invoice with a bike plus the things you DIDN'T take (ie wider wheels, tyres etc). They'd only mention relevant info, not random unrelated info. 

Therefore I'm not adding anything up. I'm reading it as it's intended to be read - they've used their own data from +20 years ago and declined based on that. 

There's absolutely no disputing that. 

FD are very picky on new customers. So while you ay think "It's because I was a customer 20 years ago" It could just as easy be you do not meet the criteria for what they want from a customer.

eskbanker

born_again said:

funkycredit said:

Not at all. They wouldn't have mentioned about their own data AND credit reference data if it wasn't pertinent. It's a bit like you ordering a bike and having an invoice with a bike plus the things you DIDN'T take (ie wider wheels, tyres etc). They'd only mention relevant info, not random unrelated info. 

Therefore I'm not adding anything up. I'm reading it as it's intended to be read - they've used their own data from +20 years ago and declined based on that. 

There's absolutely no disputing that. 

FD are very picky on new customers. So while you ay think "It's because I was a customer 20 years ago" It could just as easy be you do not meet the criteria for what they want from a customer.

But if that was the case, wouldn't they say something like "you didn't meet our account opening criteria"?

Oh wait, that's exactly what they did say....