Charter Savings Bank cash ISA account opening - not.

eskbanker

I have said that it's up to Charter Savings who they accept. I suppose that whether their conditions for proving identity reflect what other similar institutions require and whether their conditions are considered reasonable is purely subjective.

Similarity with other institutions can be measured entirely objectively by anyone motivated to do so! 'Reasonable' is obviously more of a subjective concept but again, given the compliance with industry norms, it's vanishingly unlikely that the FCA, ICO, etc, would consider them unreasonable.

Re. the P60, I expect them to do what I expect any institutions to do when sending out people's personal data - take reasonable steps to ensure that the recipient will be the person entitled to the data. Not an altogether unreasonable expectation in this day and age, I would have thought. By their own criteria, they have not as yet managed to do that. Electoral roll as a start? Two other financial institutions my wife has told Charter Savings she is a customer of?

But, thinking about it, if they did that, it would make them look pretty stupid, no?

Edit: The P60 is only with Charter Savings because they told my wife over the phone that it would be acceptable as proof. The problem of what to do with it is one ENTIRELY of their own making, and as such is one for them to sort out. If they have to send a courier with it personally, my wife will happily await them with passport in hand.

To be honest I think the 'problem' is completely imaginary! It seems to me that you're conflating two different issues, in that an institution's account opening processes will be constrained by standardised KYC policies that will involve structured ID verification, whereas simply returning a document to its sender at the address they supplied requires nothing of the sort, so I'm sure you really know that there will be no independent verification and that the ICO wouldn't have an issue with that approach.

Having said that, your wife obviously shouldn't have been given inaccurate information over the phone…

largeronald

To go back a post, I fail to see any logic in a process that deems a document acceptable evidence because it would involve 2 criminal offences in its use, whilst at the same time deems one unacceptable because it would only involve 1 criminal offence in its use. To lay this particular issue to rest; you obviously have a far greater insight into the workings of the Charter Savings mind than I, and whilst making my opinions known on the matter, I have no option but to concede the point. Part of my views on this were, again, formed in our discussions with Charter Savings. Of course the driving licence was mentioned as a source of evidence - on at least two, if not three (these discussions were very circular) occasions with different staff. In each, the conversation went along these lines:

"Do you have a driving licence?"

"Yes, but it's not a photographic one, it's an old paper one. Surely you won't accept that as proof?"

Contradiction came there none - every single time.

If we were given any indication it were acceptable, of course we would have sent it.

This is how we ended up with the P60 issue. It was suggested by me in a straw-clutching exercise and it was only advised we send it in after the agent confirmed it with their superior. Whether the conditions stated it acceptable or not, I don't think we could be blamed for thinking it would be accepted in this particular case simply in order to provide a resolution. After all, my wife had also provided the following:

Passport copy

Printed copy of a current statement from her designated bank account. The is the bank account that would be used in all transactions with Charter Savings and each transaction would carry her name, sort code and account number. It is a mystery to me what anyone could hope to gain from altering the address on it.

National Insurance number (probably for ISA tax implications). Any address discrepancy, I am sure, would be flagged up by His Majesty pdq.

Name, sort code and account number of the existing Cash ISA whose transfer would open her Charter Savings account. She also told them in her application how much money was in it. I'm sure that, if deemed necessary, my wife's address could be confirmed there.

The whole purpose of Charter Savings conditions is to provide proof of identity - indeed The Data Protection Act will probably state that that is the ONLY use that the information gleaned from them can be put to.

We have tried (and in my view succeeded), in all good faith, to provide ample proof. It might not be in strict accordance with their published conditions, but come on Charter Savings, apply a modicum of (I know, an extremely over-used phrase) common sense here.

eskbanker

It might not be in strict accordance with their published conditions, but come on Charter Savings, apply a modicum of (I know, an extremely over-used phrase) common sense here

I suspect we're in diminishing returns territory here so don't propose to go through addressing your post line by line but this bit at the end is the key really - once regulated institutions have published a policy then there's minimal, if any, latitude to contravene it, even if doing so would appear sensible to the customer. As above, if the agent had simply stated that, it would have eliminated some of the toing and froing thereafter, but I suspect that a blunt refusal along the lines of 'that's our policy, take it or leave it' also wouldn't have gone down well?