Data Privacy Policy

Data Privacy Policy

Privacy Statement

This Privacy Statement sets out how HSBC Group Management Services Limited incorporated in England and Wales with company registration number  9231974 and whose registered office is at 8 Canada Square, London E14 5HQ, (“HSBC”, “we”, “us” or “our”) uses your information and that of others (“personal data”) when you (a “User”) downloads the application from an app store, registers your HSBC email address and verifies your account with the unique passcode to be emailed to your HSBC email address for access to the HSBC news feed, detailing internal and public communications   “HSBC Now News app”.  You should read this Privacy Statement carefully before using the HSBC Now News app.  If you have any questions about how HSBC uses personal data, you should contact us using the details provided in the Contacting Us section below.

For the purposes of data protection we are a data controller in respect of your personal data. We are responsible for ensuring that we use your personal data in compliance with data protection law.

HSBC collects and uses personal data about you and other Users.  This includes information about you and others which you provide to HSBC or otherwise send or submit via the HSBC Now News app, and the information about you which others may send or submit via the HSBC Now News app.  Prior to providing HSBC with anybody else’s personal data, you must ensure that you have their consent to do so or are otherwise entitled to provide HSBC with their personal data.

HSBC’s business has been built on trust between us and our Users and customers. To preserve the confidentiality of all information you provide to us, we commit to the following in relation to such information:

We will collect and process the following personal data about you:

  • Information we collect or generate about you. This includes work-related details such as name, department, business area, employee ID, employee type, career band, work email address, work address.
  • Information that you send or submit through the HSBC Now News app. This includes information about you that you give to us by filling in forms or by communicating with us, whether face-to-face, by phone, e-mail or otherwise and/or via the HSBC Now News app. This information may include: Employee ID, contact details,. This information may include:
    • your full name details, , work address, and mobile telephone number, , , , user opt-in information, , , , , , personal interests.

Your personal data may be stored and processed by us in the following ways and for the following purposes:

  • in order to enable the effective operation of the HSBC Now News app;
  • in order to ensure that the HSBC Now News app is used in accordance with our policies and procedures;
  • in order to generate your profile and optimise your User experience, and to inform you of internal and public HSBC news and updates via the HSBC Group Communication News App;
  • in order to analyse feedback provided by you through the HSBC Now News app;
  • the management and administration of our business and our affiliates’ business;
  • assessing compliance with applicable laws, rules and regulations, and internal policies and procedures across our business and our affiliates’ businesses;
  • the administration and maintenance of the databases storing personal data relating to our employees and Users;
  • providing HSBC Now News app notifications related to your activity on the HSBC Now News app;  
  • arranging, planning and delivering internal and public HSBC news and updates via the HSBC Group Communication News App to HSBC employees;
  • processing feedback from Users relating to the HSBC Now News app; or
  • assessing the performance of the HSBC Now News app (e.g. monitoring the number of users signed up to the HSBC Now News app).

We are entitled to use your personal data in these ways because:

  • you have given your consent to the processing of your Personal Data. Once you have provided consent to the processing of your Personal Data, you will be deemed to accept the terms of this Privacy Policy every time you use the HSBC Now News app (unless you notify us that your consent has been withdrawn, though in such circumstances we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so);  
  • if applicable, you have given your consent to us creating, using, publishing, distributing or sending marketing and promotional materials to you on behalf of the HSBC Group (unless you notify us that your consent has been withdrawn, though in such circumstances we may still be entitled to process your personal data if we have a legitimate reason (other than consent) for doing so);
  • we have legal and regulatory obligations that we have to discharge;
  • we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
  • the use of your personal data as described may be necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates), such as:
  • allowing us to effectively and efficiently administer and manage the operation of our business;
  • maintaining compliance with internal policies and procedures.
  • HSBC may pass the information to other HSBC Group companies, employees or third parties, as permitted by law or for the purposes of:
  • enabling the effective operation of the HSBC Now News app;
  • ensuring that the HSBC Now News app is used in accordance with our policies and procedures;
  • generating your profile and optimise your User experience;
  • analysing feedback provided by you relating to the HSBC Now News app;  
  • the management and administration of our business and our affiliates’ business;
  • assessing compliance with applicable laws, rules and regulations, and internal policies and procedures across our business and our affiliates’ businesses;
  • the administration and maintenance of the databases storing personal data relating to our employees and Users;
  • processing feedback from Users relating to the HSBC Now News app ; or
  • assessing the performance of the HSBC Now News app (e.g. monitoring the number of users signed up to the HSBC Now News app).

We will take steps to ensure that the personal data is accessed only by employees of our affiliates that have a need to do so for the purposes described in this notice.

HSBC will not disclose the information to any external organisation unless: (1) HSBC has User consent; (2) HSBC is required to do so by law (for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, establish, exercise or defend our legal rights); or (3) for one of the reasons set out below.

We may share your personal data with third parties outside of our corporate group as follows:

  • with third party providers for administration purposes and running of the HSBC Now News app;
  • to third party agents and contractors for the purposes of providing and maintaining the Group Communications News App. These third parties will be subject to confidentiality and data protection requirements and they will only use your personal data as described in this privacy notice;
  • to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, establish, exercise or defend our legal rights;
  • where we may be required, from time to time, to disclose the information to governmental or judicial bodies or agencies or HSBC’s regulators but HSBC will only do so under proper authority; or

HSBC aims to keep the information up-to-date.

HSBC maintains strict security systems designed to prevent unauthorised access to the information by anyone, including HSBC staff.

All HSBC group companies, or HSBC staff and all third parties with permitted access to the information, are specifically required to observe HSBC’s confidentiality obligations.

References above to ‘information’ shall be deemed to include personal data.

Personal data may be disclosed or transferred and/or stored outside the European Economic Area (“EEA”) worldwide for the purposes of:

  • providing the HSBC Now News app to you, including:
    • providing and operating the HSBC Now News app in accordance with the terms and conditions for the HSBC Now News app, and
    • moderating the content of the HSBC Now News app (including the content of all profiles, posts ,endorsement);
  • defending the HSBC Group against legal or regulatory claims or action;
  • subject to you providing your separate consent for us to do so creating, using, publishing, distributing, or sending marketing and promotional material to you on behalf of the HSBC Group;
  • verifying your identity and that of others;
  • preventing and detecting crime;
  • compliance with any legal and/or regulatory obligations to which HSBC is subject;
  • complying with appropriate governmental and non-governmental regulators or ombudsman;
  • other legitimate business purposes of HSBC Group; and
  • any further purposes notified to and/or agreed with you and/or the entity you represent from time to time.

Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:

  • the country that we send the data to might be approved by the European Commission as offering a sufficient level of protection;
  • the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data; or
  • where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme.

In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details about the protection given to your personal data when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contacting us” section below.

How long we hold your personal data for will vary. The retention period will be determined by the following criteria:

  • the purpose for which we are using your personal data – we will need to keep the data for as long as is necessary for that purpose; and
  • legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

Personal data may still be retained and processed if you are not determined by us to be an eligible User.  Any such data will be retained in accordance with applicable law and processed for the purposes set out herein.

You have a number of legal rights in relation to the personal data that we hold about you. These rights include:

  • the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
  • the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that (as set out above) we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so.
  • in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
  • the right to request that we rectify your personal data if it is inaccurate or incomplete;
  • the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
  • the right to request that we restrict our processing of your personal data in certain circumstances. Again, there may be circumstances where you ask us to restrict our processing of your personal data but we are legally entitled to refuse that request; and
  • the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the “Contacting us” section below.

Contacting us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to: Mobile.news@hsbc.com    

You can find out more information about your rights by contacting the data protection regulator in your jurisdiction.

You can view the Cookie Policy here https://www.hsbc.com/cookie-policy/

Last updated: xx.xx.2018