First Direct- eligibility 6 December 2022 at 5:36PM in Budgeting & bank accounts 12 replies 614 views

stevehyn12

First Direct say if you have ever had an account with them before, then you are not eligible for a switching bonus.

But how far back could they reasonably check for this? Would they not have to delete older customer data (say from beyond 7 years) so would have no way to check this ?

PRAISETHESUN

Anecdotally, FD have a long memory. I've seen people report being declined an incentive due to an account they held 20+ years ago, but I've also seen instances of people falling through the cracks and getting incentives they technically shouldn't be eligible for - your mileage may vary.

Band7

stevehyn12 said:

 Would they not have to delete older customer data (say from beyond 7 years) so would have no way to check this ?

There is no maximum retention period. A company can keep records for as long as they wish. The law says that a business should keep information for “no longer than is necessary”. FD appear to consider it necessary to ensure nobody gets a switch bonus more than once. Therefore it is necessary they keep your data for a long time. Whether they eventually delete it, I don't know. 

eskbanker

stevehyn12 said:

Would they not have to delete older customer data (say from beyond 7 years) so would have no way to check this ?

It's permissible to keep some data for significantly more than seven years if their data retention policy is justifiable, so they can (and presumably do) argue that they have a business requirement to retain a record of the fact that someone had an account, even though all the transactional detail, etc, would be purged more regularly.

stevehyn12

I'm not sure you could justify holding data permanently on the off chance someone tries to apply again in the future. 

[Deleted User]

stevehyn12 said:

I'm not sure you could justify holding data permanently on the off chance someone tries to apply again in the future. 

You could easily hold extremely limited data that simply said person X had an account between dates Y and Z

cymruchris

eskbanker said:

stevehyn12 said:

Would they not have to delete older customer data (say from beyond 7 years) so would have no way to check this ?

It's permissible to keep some data for significantly more than seven years if their data retention policy is justifiable, so they can (and presumably do) argue that they have a business requirement to retain a record of the fact that someone had an account, even though all the transactional detail, etc, would be purged more regularly.

Although not FD - I can confirm absolutely that banks/credit card providers do keep data for longer than 7 years. I recently submitted a data subject access request to MBNA as I was interested whether they still hold the information pertaining to my bankruptcy in 2013, and anything prior. I received a pack around 300 pages thick containing details of all my accounts, copies of statements and lots more dated from 2010 onwards, so that's 12 years they've kept my history even though my financial connection ended with them in 2013. (I did it as I was always coming up as 0% eligibility for any credit cards - so was interested to know 'how much' they remembered - and the answer was 'lots')

I'm sure each financial institution is different - but there's no doubt in my mind that they'll all have history that goes back a long, long way. 

Band7

stevehyn12 said:

I'm not sure you could justify holding data permanently on the off chance someone tries to apply again in the future. 

I am very sure that they can.

eskbanker

stevehyn12 said:

I'm not sure you could justify holding data permanently on the off chance someone tries to apply again in the future. 

They obviously don't describe it in those specific terms but will rely on the vagueness of the wording of their privacy policy, with its careful use of 'for example' and 'eg' (not sure why they feel the need to use both!):

We keep your information in line with our data retention policy. For example we'll normally keep your core banking information for a period of 7 years from the end of our relationship with you. This enables us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes eg managing your account and dealing with any disputes or concerns that may arise. 

We may need to retain your information for a longer period where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate purposes eg to help us respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators etc. 

If we don't need to keep information for this long we may destroy, delete or anonymise it more quickly. 

Katiehound

A few years ago I asked about this and the person I spoke to wasn't able to trace me- same name & address very many years later.  I think I asked if you were refused if you had EVER had an account with them & the answer was NO. Still not convinced!
When I closed the account I asked them to delete my name from their records but they refused!

If the method they used to confirm  identity was easier I may well have tried to get a switch bonus recently but for the technologically challenged it was just a challenge too far.

eskbanker

Katiehound said:

I think I asked if you were refused if you had EVER had an account with them & the answer was NO. Still not convinced!

They've always been pretty clear in their offer wording, which currently states "New customers to first direct only, who have not previously held a first direct product", without any reference to 'within the last n years' or 'since <date>', as used when cross-referring to HSBC customers.