{"type":"document","data":{"id":"b1fdd75d-3bb7-40a3-9bdd-4ef28842c3ba","localeString":"en-GB","publishDate":"2025-12-15T12:17:40.948+01:00","contentType":"onecms:productPage","hasMacro":false,"flexPageMetadata":{"afmBanner":false,"robotInstruction":{"noIndex":false,"noFollow":false},"description":"Waarvoor gebruikt ING persoonsgegevens?"},"mainHeaderZone":{"componentType":"productHeader","coreHeader":{"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":"3. What we do with your personal data","subtitle":"Processing means every activity that can be carried out in connection with personal data such as collecting, recording, storing, adjusting, organising, using, disclosing, transferring or deleting it in accordance with applicable laws."},"backLink":{"textLink":{"url":"/en/bank/privacy-statement","text":"ING and your personal data"}}},"flexZone":{"flexComponents":[{"componentType":"paragraph","richBody":{"value":"<p>We use your personal data for:</p>"}},{"componentType":"accordion","accordionList":[{"title":"Performing agreements to which you are a party or taking steps prior to entering into these agreements","richBody":{"value":"<p>We use your personal data when you enter into an agreement with us, or when we have to execute our obligations under these agreements.</p><p>For instance, we use your account details when you ask us to make a payment or carry out an investment order or to provide you with statements of your accounts or your annual overview in My ING. We also use these account details to block payments, investigate and remediate product dysfunctionalities and solve claims, petitions and complaints regarding the requested services, when necessary. We also use your personal data to contact you in order to notify you of issues such as contractual term changes, the expiry of a deadline/contractual condition, registering a debt or to provide you with information related to your services/relationship.<br /><br />We rely on the lawful basis of ‘necessary for performing agreements’ when we use your personal data for these and compatible purposes.</p><p> </p>"}},{"title":"Compliance with our legal obligations","richBody":{"value":"<p>We use your personal data to comply with a range of legal obligations and statutory requirements, including banking and financial regulations that oblige us to perform or provide:</p><ul><li><strong>Integrity checks: </strong>when entering into a customer relationship with you, we have a legal obligation to consult available incident registers and warning systems and national and international sanctions lists.</li><li><strong>Identity verification:</strong> when entering into a customer relationship with you, we have a legal obligation to confirm your identity (know your customer check). We can do this by making a copy of your identity document, which we will only use for identification and verification purposes. We may also rely on checks performed by other financial institutions to verify your identity.</li><li><strong>Credit checks:</strong> before entering into a customer relationship with you, we have a legal obligation to check whether you qualify as an eligible customer. We assess your credentials from a risk perspective and predict if you can meet your financial obligations towards us as set out in Section 6 (Automated decision-making and profiling). <span><span><span>In case of lending activities, information on address or geo-location details may be processed in order to ascertain the risk in the event of natural disasters.</span></span></span></li><li><strong>Fraud prevention and anti-money laundering and terrorism financing checks:</strong> we have a legal obligation to check for potential fraud, money laundering and terrorism financing. This includes monitoring unusual transactions and sanctions lists as set out in Section 6 (Automated decision making and profiling).</li><li><strong>Regulatory and statutory reports to our regulators</strong> as set out in Section 4 (Who we share your personal data with and why).<p>We rely on the lawful basis of ‘necessary to comply with a legal obligation’ when we use your data for these processing activities.</p></li></ul>"}},{"title":"Our legitimate interest","richBody":{"value":"<p>We process your data for a range of purposes that are in our interests as described below. When relying on legitimate interest, we ensure that processing remains proportionate and that your interests, fundamental rights and freedoms are respected. If you would like more information about our reasoning behind our assessment in a specific case, please contact us using the details provided in Section 11 (Contact and questions). Please find below an overview of the purposes for which we process your personal data where we rely on legitimate interest:</p><ul><li><strong>To develop and improve our products and services.</strong> <span><span><span>We may use data collected through analytical cookies and similar tracking technologies when analysing your visit to our website or app with the aim of improving these. No consent is requested for the use of analytical cookies that have little or no impact on visitor privacy. If analytical cookies do impact your privacy, we will ask for your consent. For more information, we refer to our Cookie Statement as published on ing.nl/privacy.</span></span></span> <br /><br />We  may also use your personal data to develop and maintain various types of models, such as credit risk models.<br /><br />Besides we will ask you for your feedback on our current products and services or ask for your opinion on new product ideas. This can include recording your conversations with us, but we will always inform you about this beforehand, unless this is not allowed according to local law.</li><li><strong>To promote and offer you the best-suited products and services provided by us or other ING entities.</strong> We will process your personal data when informing or advising you about similar products and services from ING, including in the areas of sustainability and financial health. Of course, if you do not want to receive these offers you have the right to object or to opt out. We strive to understand you better and meet your changing needs by offering you services that will suit your specific situation. To achieve such personalisation, we may:<ul><li>take into account your sociodemographic and financial situation;</li><li>take into account your preferences and interactions in our various communications channels; </li><li>analyse the products and services that you have already purchased from us.</li></ul></li><li><p><span><span><span><strong>To assess and manage credit risk.</strong> We use your personal data to develop and apply credit risk models and risk analyses that help determine whether you can meet current and future financial obligations, such as loans or mortgages. These models also enable ING to identify early signs of payment difficulties and support your financial health. This helps protect both you and ING from problematic debts. In addition, ING uses these models to report on at the portfolio level to regulators.</span></span></span></p></li><li><p><span><span><span><strong>To ensure accurate financial reporting.</strong> We process your data to calculate the likelihood that loans may not be repaid or may be repaid late, which is essential for producing accurate annual financial statements, including the Profit and Loss account and balance sheet. While your data is used to develop and maintain credit risk models, only aggregated information is included in financial reports, that cannot be traced back to you.</span></span></span></p></li><li><strong>To protect you and ING from fraud. </strong>We process your data to detect and prevent fraud. Examples are:<ul><li>During a phone call you can check via a button in the app/My ING to check if you are in a call with ING.</li><li>While you are banking online, we may run checks on your devices to determine if there are indications of fraud, such as a different SIM card being used for a particular mobile number.</li></ul></li><li><strong>To keep the financial sector safe.</strong> <span><span><span>ING takes protective measures. For example, ING maintains event records. Events that pose a serious risk are recorded. Personal data of (legal) persons involved in such events may be included in the Internal Referral Register (IVR) linked to the internal event administration. The event records and the IVR can only be accessed by authorized teams within ING and subsidiaries. </span></span></span><br /><br /><span><span><span>ING also cooperates with other financial institutions via participation in the “Financial Institutions Incident Warning System.” Through this system, it is possible for member financial institutions to investigate and verify whether someone (for example, a customer or job applicant) poses or may pose a threat to the (customers or employees of the) financial institution. For example, if someone has previously been involved in fraud or scams at a financial institution. This will prevent this person from trying again at another financial institution. As part of this warning system, ING maintains an internal incident register in which incidents are recorded. </span></span></span><br /><br /><span><span><span>ING may register personal data of data subjects in the “External Referral Register” (EVR) to alert other participating financial institutions. The processing takes place in accordance with the “Protocol Incident Warning System Financial Institutions” (PIFI), approved by the Dutch Data Protection Authority. ING can, if there is sufficient reason to do so, check whether someone is listed in the IVR or EVR. This is done via an ‘EVA test’: EVA is the computer system used by financial institutions to check whether someone is listed in the IVR and/or EVR. If ING chooses to include someone in the IVR or EVR, the person concerned is informed by letter. This letter includes information about the reason for the proposed registration, the possible consequences and how to object.</span></span></span></li><li><strong>To ensure effective and efficient internal business process execution and management reporting.</strong> We process your data for our internal processes and operations and to help our management to make better data-driven decisions about our operations and services. We will always choose aggregated data for this if we can, so that you are not identifiable. This includes:<ul><li>analysing our market position in different segments;</li><li>analysing credit risks;</li><li>training our staff, for example by analysing recorded phone calls (if recording is permitted by local law) in our call centres to improve our calling scenarios;</li><li>automating our processes such as application testing, automatic filling of complaints handling;</li><li>conducting litigation and complaint management;</li><li><p><span><span><span>meeting our environmental, social and governance (reporting) commitment;</span></span></span></p></li><li><p><span><span><span>examining whether new rules have been properly implemented, to determine whether processes are being done properly, or to identify risks associated with a process.</span></span></span></p></li></ul></li></ul>"}},{"title":"To protect your vital interests","richBody":{"value":"<p>We process your data when necessary to protect your interests which are essential for your life or that of another natural person. For example for urgent medical reasons pertaining to you. We will only process your personal data necessary for the vital interests of another natural person if we cannot base it on one of the other purposes mentioned.</p>"}},{"title":"To respect your choice if we request your consent for specific personal data","richBody":{"value":"<p>For certain types of personal data processing, we will provide you with specific information about the process and request your prior consent before processing your personal data. This may include:</p><ul><li>The use of biometric data such as face or fingerprints for authentication and/or verification purposes.</li><li>Recording your conversations with us online, by telephone or in our branches.</li><li>The use of your transaction data (withdrawals and transfers) to show you the most relevant <a href=\"https://www.ing.nl/particulier/digitaal-bankieren/app/meer-op-maat\">tips and offers</a> for ING products and services and to give you more <a href=\"https://www.ing.nl/en/personal/digital-banking/app/insights\">insight</a> into your banking affairs. Does one of the joint account holders provide consent for the use of transaction data? Then we will inform the other account holder(s).</li><li><p><span><span><span><span lang=\"en-NL\" dir=\"ltr\"><span>The use of your personal and financial data to assess whether your mortgage is still suitable for your current and future situation. In this way, we can help you identify possible risks at an early stage and act where necessary.</span></span></span></span></span></p></li><li><p><span><span><span>Collection of your personal data with cookies and similar tracking technologies when you visit our websites or the ING app. If you are a customer and with your permission, we may combine information collected through cookies with information about ING products you have or services you use. This means we can show you content and offers that are more relevant to your needs. For more information, we refer to our Cookie Statement as published on ing.nl/privacy.</span></span></span></p></li></ul><p>You may change or withdraw your consent at any time.</p>"}},{"title":"For scientific research or statistical purposes","richBody":{"value":"<p><span lang=\"EN-US\" dir=\"ltr\"><span><span>We may also process your personal data if necessary for scientific research or statistical purposes. For example, ING conducts research on relevant economic or market developments. In addition, ING conducts research on the contribution of its products to the financial health of customer groups or the impact on the climate, for example. </span></span></span><span><span><span>Results are used for strategic reports and for product development. </span></span></span><span lang=\"EN-US\" dir=\"ltr\"><span><span>In doing so, appropriate technical and organizational measures are taken to protect your privacy. Examples of measures include pseudonymizing or anonymizing your personal data. This kind of studies may also be published. These publications will never include data that can be traced back to individuals.</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"}]}]}}}