We’re committed to delivering best-in-class, simple banking experiences for our Clients. Part of how we do that is through data and analytics that allow us to provide innovative, personalized services, while also protecting our Clients and ourselves against fraud, financial crime and risk. At the core of all of this is our commitment to ensuring the responsible and ethical use of technologies, data and Client information.

We’ve created this Data Ethics Commitment to help ensure that we’re safeguarding our Clients’ data and using it for their benefit throughout the full data lifecycle. Our practice is guided by the following Data Ethics Principles:

1. Useful – We gather and use data to manage our business and deliver value for our Clients and the communities that we serve.

2. Adaptable – We operate in a changing landscape where policy and social expectations are changing. We continually monitor global developments to ensure that our data practices are in line with global best practices and our core principles.

3. Accountable – We see ourselves as stewards of our Clients’ data, and our internal policies ensure that data owners are defined and accountable for every project.

4. Transparent – We clearly communicate to our Clients and employees about how their data is collected, used and stored.

5. Respectful – We believe that individuals have a right to be treated fairly and respectfully, and not to be discriminated against or exploited. We take great care to control for and mitigate any potential historical bias as we collect, use and disclose data to ensure fairness in decision outcomes.

6. Safe – We protect Client data with appropriate security controls to ensure we’re adhering to bank policies and to minimize the risk of breach. Our teams keep abreast of relevant laws and codes of practice that relate to the use of data and implement them as appropriate.