{"type":"document","data":{"id":"6ba98577-e852-4a49-b7d8-8a38c007f4a0","localeString":"en-GB","publishDate":"2025-09-30T10:49:31.447+02:00","contentType":"onecms:productPage","hasMacro":false,"flexPageMetadata":{"afmBanner":false,"robotInstruction":{"noIndex":false,"noFollow":false},"description":"Automated decision making, profiling and use of AI"},"mainHeaderZone":{"componentType":"productHeader","coreHeader":{"body":"Since we serve a wide group of customers, it makes the use of automated decision-making,  profiling and the use of Artificial Intelligence (AI) sometimes necessary. Examples \r\nare:","headerImage":{"transformBaseUrl":"https://assets.ing.com/transform/e8c1a682-6836-4ed6-a578-df27d7e93423/Two-male-friends-with-their-mountain-bikes-in-the-countryside","type":"image","width":6109,"original":"https://assets.ing.com/m/14f9ce7d36f2330/original/Two-male-friends-with-their-mountain-bikes-in-the-countryside.jpg","extension":"jpg"},"title":"6. Automated decision-making, profiling and use of AI","subtitle":"Automated decision-making is when we make decisions by technological means without significant human  involvement. Profiling involves the automated  processing of personal data with a view to evaluating or  predicting personal aspects such as the economic  situation, reliability or likely behaviour of a person."},"backLink":{"textLink":{"url":"/en/bank/privacy-statement","text":"ING and your personal data"}}},"flexZone":{"flexComponents":[{"componentType":"paragraph"},{"componentType":"accordion","accordionList":[{"title":"Credit risk rating","richBody":{"value":"<p>When you apply for a loan or credit, we create a profile to assess whether you can meet your financial obligations to us and to ensure that we do not offer loans that are not suitable for you. We assess the risk connected to a contract with you via a method called credit scoring. Your credit score is calculated based on automated decision-making. You have to achieve a pre-defined minimum score to ensure an acceptable risk for us. <span><span><span><span lang=\"EN-US\" dir=\"ltr\">Even after the loan has been granted, we calculate the risk that you may not be able to repay it. We call this the “credit risk”.</span></span></span></span></p><p>The credit score is calculated mainly on your financial standing. Based on the personal data you provide in the credit-scoring process, we consult external credit rating agencies to acquire relevant financial information (credit rating, financial statements, turnover/solvency, payment history). If you already have or had a relationship with us in the past, (taking into account applicable retention periods), we combine the external financial information with your internal payment history. If you do not achieve the minimum score, the automated credit scoring will decline your application. In that case, we will not enter into an agreement with you since we consider the risks for you and us to be too high. You have the right to object to such automated decisions and request a manual (non-automated) review by a person. We refer to section 7 (Your rights and how we respect them) on how to do this. </p><p> </p><p> </p>"}},{"title":"Prevention of fraud and money laundering and terrorism financing","richBody":{"value":"<p>We are obliged to perform customer and transaction screening to detect potential and actual criminal activity. As a result, we pay particular attention to unusual transactions and to transactions that, by their nature, result in a relatively high risk of fraud, money laundering or financing of terrorism. To do this we create and maintain a risk profile for you. If we suspect that a transaction is connected with money laundering or terrorist financing, we are obliged to report this to the authorities.</p><p>Examples of factors that we take into account that may indicate an increased risk of fraud or money laundering and terrorist financing are:</p><ul><li>Changes in a person’s normal spending and payment behaviour, such as unexpectedly large amounts being transferred or debited.</li><li>Payments to or from suspicious countries, stores or addresses.</li><li>Two PIN payments by a single person in two vastly different locations at the same time.</li><li>Being listed on the &quot;External Referral Register&quot; (EVR). This register is a list of financial institutions in the Netherlands that includes persons and institutions who have committed fraud, have been involved in scams or otherwise pose a risk to the financial sector. Affiliated financial institutions in the Netherlands can check whether persons and institutions are on the list and they can add them to the list. Here the rules of the Protocol Incident Register Financial Institutions (PIFI) apply. These rules have been approved by the Dutch Data Protection Authority.</li><li>Being listed on any public national or international sanctions lists.</li></ul><p> </p>"}},{"title":"Use of Artificial Intelligence (AI)","richBody":{"value":"<p><span lang=\"en-NL\" dir=\"ltr\"><span><span>We may use AI to improve our services. For example, AI is used to improve application processes. Also, chatbots are used to help customers. AI can also be used in other areas, such as preventing financial crime and fraud. Personal data may be processed when using AI and researching its possibilities, as well as for the purpose of developing AI. When  doing so, we always ensure that appropriate safeguards are in place.</span></span></span></p>"}}]},{"componentType":"paragraph"},{"componentType":"linkList","iconTitle":{"title":"Privacy Statement"},"textLinks":[{"url":"/en/bank/privacy-statement/about-this-privacy-statement","text":"About this Privacy Statement"},{"url":"/en/bank/privacy-statement/introduction","text":"Introduction"},{"url":"/en/bank/privacy-statement/purpose-and-scope-of-this-privacy-statement","text":"1. Purpose and scope of this Privacy Statement"},{"url":"/en/bank/privacy-statement/the-types-of-personal-data-we-process","text":"2. The types of personal data we process"},{"url":"/en/bank/privacy-statement/what-we-do-with-your-personal-data","text":"3. What we do with your personal data"},{"url":"/en/bank/privacy-statement/who-we-share-your-data-with-and-why","text":"4. Who we share your data with and why"},{"url":"/en/bank/privacy-statement/transfer-of-personal-data-outside-the-eea","text":"5. Transfer of personal data outside the EEA"},{"url":"/en/bank/privacy-statement/automated-decision-making-and-profiling","text":"6. Automated decision-making, profiling and the use of AI"},{"url":"/en/bank/privacy-statement/your-rights-and-how-we-respect-them","text":"7. Your rights and how we respect them"},{"url":"/en/bank/privacy-statement/how-long-we-keep-your-personal-data","text":"8. Retention"},{"url":"/en/bank/privacy-statement/how-we-protect-your-personal-data","text":"9. How we protect your personal data"},{"url":"/en/bank/privacy-statement/changes-to-this-privacy-statement","text":"10. Changes to this Privacy Statement"},{"url":"/en/bank/privacy-statement/contact-and-questions","text":"11. Contact and questions"}]}]}}}