Protecting your personal data.

We may collect the following types of personal data about you. In this privacy notice, “You” refers to you as an individual, as relevant if you are:

• a personal banking client;
• a representative of, or an individual directly or indirectly related to or associated with: (i) a company, business or organisation that is our personal banking client; or (ii) a person or a company, business or organisation that has a relationship with our personal banking client; or
• a representative of, or an individual directly or indirectly related to or associated with: (i) a company, business or organisation that is our business or corporate banking client; or (ii) a person or a company, business or organisation that has a relationship with our business or corporate banking client.

Personal data we collect with respect to business and corporate client relationships is primarily limited to the information on directors and officers, other employees, direct and indirect beneficial owners and authorised persons we need to enable us to meet our due diligence obligations, signatory details and contact information of individuals we interact with to enable the provision of products and services to clients.

If you give us someone else’s personal data, you must have their permission and explain to them how we’ll use it.

We may collect the following types of personal data about you, as relevant and allowed by law:

• Identification datainformation that identifies (uniquely or semi uniquely) you. For example, your name, your date of birth, your gender, your user login credentials, your photographs, CCTV and video recordings of you and other identifiers, including official/government identifiers such as national identification number, passport number and tax identification number
• Contact datainformation that allows addressing, sending or communicating a message to you. For example, your email address, your phone or mobile number and your residential or business address
• Professional datainformation about your educational or professional background
• Financial and commercial datayour account and transaction information or information that identifies your financial position and background, status and history as necessary to provide relevant products and services. For example, your debit or credit card details, your source of funds, your financial and credit rating history
• Geo-location datainformation that provides or contains a device’s location. For example, your internet protocol (IP) address or your cookies identifier
• Behavioural dataanalytics information that describes your behavioural characteristics relating to your use of our products and services. For example, usual transactional activities, browsing behaviour on our websites and how you interact as a user of our products and services, or those provided by third-party organisations, such as our advertising partners and social media platform providers
• Personal relationship datainformation about associations or close connections between individuals or entities that can determine your identity. For example, spouse or employer relationships
• Communications datainformation relating to you contained in voice, messaging, email, live chats and other communications we have with you. For example, service requests.

We may sometimes need to collect special personal data about you, but we only do this if it’s necessary and with your consent, or where allowed by law. This special personal data may include things like:

• Racial or ethnic origin datainformation which reveals your racial or ethnic origin
• Biometric datainformation that identifies you physically. For example, facial recognition information, your fingerprint or voice recognition information. Face data collected through the mobile application. The mobile application may collect a standard image captured through the device’s front facing camera for identity verification and related regulatory or security purposes. The application does not use machine learning or facial recognition capabilities to analyze the image. Face data is collected only to the extent necessary for the stated purpose.
• Health datainformation relating to your health status. For example, disability information relevant to accessibility
• Criminal convictions, proceedings or allegations datainformation about criminal convictions or related information that we identify in relation to our financial crime prevention obligations, for example, details about any criminal convictions or related information. This includes details of offences or alleged offences or convictions.

We usually get your personal data directly from you, but we may also obtain your personal data from other sources as necessary, depending on the relevant products and services that we are providing, including from:

• People you know – such as:
  • parents or guardians of minors. If you are a minor (normally this means if you are under 18 years old, but this might be younger depending on where you live). We will get your parent or guardian’s consent before collecting, using or sharing your personal data
  • your joint account holders
  • your referees; and
  • other people you appoint to act on your behalf
• Businesses and other organisations – such as:
  • your employer and/or company, business or organisation you represent or is related to you
  • other financial institutions and financial service providers
  • strategic referral partners, including business alliance, co-branding partners or other companies or organisations that the Ahantaman Community Bank PLC cooperates with based on our contractual arrangements or other joint ventures to provide relevant third-party products and services
  • service partners, such as advertising and market research companies and social media platform providers
  • credit reference and fraud prevention agencies
  • regulatory and other entities with authority over the Ahantaman Community Bank PLC, such as tax authorities, law enforcement or authorities imposing financial sanctions
• Our corporate and business clients – where you receive the benefit of our services in relation to our contract with the company, business or organisation you interact with. For example, resolving payment disputes with our merchant clients
• Publicly available resources – such as online registers or directories or online publications, social media posts and other information that is publicly available

Cookies – when you visit, browse, or use our websites, online banking or mobile applications, we may use cookies to automatically collect certain information from your device. We may use such information, where relevant, for internal analysis and troubleshooting, to recognise you and remember your preferences, to improve the quality of and to personalise our content and to determine the security status of your account. For more information on how we use cookies and how you can control them when visiting our websites, please see our Cookie Policy.

We collect your personal data so that we can provide our products and services, manage our relationship with our clients and operate our business. This is necessary when you hold your own bank account with us and also when you represent, or are associated with, other individuals, companies, businesses or organisations who bank with us, for example, if you act as a guarantor, employee, shareholder, director, officer or authorised person.

If you have or are associated with more than one account with Ahantaman Community Bank PLC, we may link all your accounts and personal data to enable us to have an overall picture of our client relationships.

What we use your personal data for is often referred to as our purposes of processing and these are detailed below. We generally process your personal data with your consent where required by law or where otherwise permitted or required by applicable law.

We may not be able to offer or provide our products and services if you do not provide us with the necessary personal data or do not want us to process the personal data that we consider is necessary and/or is required to meet our legal and regulatory obligations.

Purposes of Processing

We process your personal data for the following purposes, as necessary to provide relevant products and services, depending on whether you have your own bank account with us or you represent, or are associated with, other individuals, companies, businesses or organisations who bank with us.

For further information on direct marketing, please refer to ‘When do we conduct direct marketing?’ section of this privacy notice.

We may sometimes, and with your consent by providing additional privacy notice information as required by applicable law, use your contact details to send you relevant marketing communications (such as by post, email, telephone, SMS, secure messages, mobile app or social media) for direct marketing purposes.

We may send the following types of communications (unless you have informed us that you do not wish to receive such communications):

• news, offers and promotions about our or other Ahantaman Community Bank PLC products and services
• information about products and services from or relating to third parties, such as financial institutions, insurers, credit card companies, securities and investment, mobile wallets and digital payment services providers
• details of our or relevant third-party reward, loyalty or privileges programmes and related services and products
• information about products and services offered by our co-branding partners (the names of such co-branding partners can be found in the application form(s) for the relevant products and services, as the case may be)
• market research and customer satisfaction surveys
• information about our or relevant third-party competitions and lucky draws
• appeals by us or relevant third parties for charitable and/or non-profit making donations, sponsorships and contributions; and
• information and communication relating to our or relevant third-party seminars, webinars and other relevant events or opportunities.

We may conduct market research using demographic and insights analytics by aggregating the personal data that we hold about you to provide you with marketing communications, which are more relevant and tailored for you.

We may share limited information about you with social media platform providers we engage with for the purpose of online social media advertising where you have permitted us and the social media platform provider(s) to use cookies that support our marketing on these platforms. For example, to check whether you have an account with social media platform providers to ask them to display more relevant marketing communication messages to you about our products and services or to exclude you from receiving advertisements for our products and services which you already use.

For more information on how we use cookies in relation to marketing, please see our Cookie Policy.

You may withdraw your consent or opt-out from receiving such marketing communications in accordance with your rights by contacting us using the details in the ‘How to get in touch’ section below.

We may use the personal data we collect to conduct data analytics, including profiling and behavioural analysis, to make quicker automated decisions in our business operations and to evaluate your personal characteristics to predict outcomes and risks. We require that rules followed by such automated systems are designed to make fair and objective decisions. We may use artificial intelligence and machine learning to help improve our communications and client experience, make our business operational processes safer and more efficient and enable us to provide faster responses and improve turnaround time. For example, we may use automated decision-making for the following:

• Client digital onboarding processes – account opening approval processes using electronic Know-Your-Customer (eKYC) checks by verifying the authenticity of scanned identification documents and a photo through biometric facial recognition and liveness check
• Operational efficiency – voicebots for call centre identification verification
• Client engagement – client marketing campaigns and communications to recommend more tailored products and services based on insights from your personal data and your interactions with robo advisors and chatbots.
• Risk management – monitoring of accounts and transactions to detect unusual activities to prevent fraud or money laundering, terrorism and other financial crimes (for example, detecting whether the use of your credit card may be fraudulent) and approval of loan applications and credit decisions based on credit-scoring models.

For further information on your rights in relation to automated decisions that affect you, please refer to the ‘What are your personal data protection rights?’ section.

We may share your personal data within the Ahantaman Community Bank PLC branches. We may share your personal data for the purposes of processing as set out in this privacy notice, including with our service providers, our business partners, other third parties and as required by law or requested by any authority. Who these are depends on your interactions with us as an individual.

We limit how, and with whom, we share your personal data, and take steps to ensure your personal data is kept confidential and protected when we share it. We may share your personal data for our purposes of processing with the following, where relevant and allowed by law:

• Other members of the Ahantaman Community Bank PLC
• Authorised third parties
  • legal guardians, joint account holders, actual or intended guarantors/sureties, trustees, beneficiaries, executors, legal representatives or authorised persons of our clients, any actual or potential participants or sub-participants in relation to any of our obligations in respect of any banking agreement, assignees, novatees or transferees (or any officers, employees, agents or advisers of any of them)
  • any other person you have authorised us by your consent to share your personal data with.
• Third parties that can verify your information
  • credit bureaus or credit reference agencies (including the operator of any centralised database used by credit reference agencies), credit protection providers, rating agencies, debt collection agencies, fraud prevention agencies and organisations
  • other non-government third parties’ that conduct financial crime prevention databases checks to prevent money laundering, terrorism, fraud and other financial crimes.
• Our service partners
  • professional advisers such as auditors, legal counsel, conveyancers and asset valuation specialists
  • insurers or insurance brokers
  • service providers, such as operational, administrative, data processing and other technology service providers, including anyone engaged or partnered with to analyse and facilitate improvements or enhancements in Ahantaman Community Bank PLC’s operations or provision of products and services
  • providers of professional services, such as market researchers, forensic investigators and management consultants
  • advertising companies and social media platform providers
  • third-party product providers, for example, securities and investments providers, fund managers and insurance companies
  • third-party service providers, such as telemarketing and direct sales agents and call centres.
• Strategic referral partners
  • business alliance, co-branding partners or other companies or organisations that the Ahantaman Community Bank PLC cooperates with based on our contractual arrangements or other joint ventures to provide relevant third-party products and services
  • charitable and non-profit organisations.
• Other financial services organisations
  • other financial institutions, such as ARB APEX BANK, correspondent banks or national banks
  • market infrastructure providers and securities clearing providers
  • payment service providers, including mobile wallet and digital payment service providers, merchants, merchant acquiring companies, credit card companies, payment processors and card association members, payment-initiation and card-based payment instrument service providers such as VISA and Mastercard
  • Account Information Service Providers (AISP)
  • any financial institution and merchant acquiring company with which you have or propose to have dealings.
• Government authorities and law enforcement
  • as required by law or as requested by any authority, which includes any government, quasi-government, regulator, administrative, regulatory or supervisory body, court, tribunal, enforcement agency, exchange body or domestic or foreign tax authorities, having jurisdiction over any Ahantaman Community Bank PLC member whether within or outside your jurisdiction and whether or not that Ahantaman Community Bank PLC member has a relationship with you
  • self-regulatory or industry bodies or associations of financial services providers in any relevant jurisdiction where the Ahantaman Community Bank PLC operates.
  • for face data collected through the mobile application, we may share the relevant face data directly with the National Identification Authority (NIA) where required for identity verification or applicable regulatory purposes. Face data will not be sold, rented, or disclosed to third parties for advertising or unrelated commercial purposes.
• Other third parties
  • the individual, company, business or organisation, as applicable, that you represent or is related to you
  • third parties in case of a merger, acquisition or divestment: if we transfer (or plan to transfer) or assign any part of our business or assets. If the transaction goes ahead, the interested party may use or disclose your personal information in the same way as set out in this privacy notice, and subsequently notify you of any changes they may make in terms with how they process your personal data
  • any other person under a duty of confidentiality to us, including any other members of the Ahantaman Community Bank PLC, which has undertaken to keep such information confidential.

Your personal data may be processed, stored, shared, transferred or disclosed by us within the Ahantaman Community Bank PLC branches or with other third parties for the purposes described in this privacy notice. We do this in order to operate effectively, efficiently and securely in facilitating transactions and providing products and services to our clients, to improve and support our processes and business operations and to comply with our legal and regulatory obligations. This may involve processing, storing, sharing, transferring or disclosing your personal data cross border to other jurisdictions.

Where recipients of your personal data are in jurisdictions that are outside Ghana, and local laws may not have similar data protection laws as Ghana, we will take all reasonable steps necessary to ensure that your personal data has an appropriate adequate level of protection and safeguards to comply with applicable law.

Face data collected through the mobile application is stored in Ahantaman Community Bank PLC’s on-premises data centre in Ghana. Such face data will not be transferred outside Ghana unless the transfer is specifically authorized and appropriate security and data protection safeguards have been established.

We take the privacy and security of your personal data very seriously. To protect your data, we have put in place a range of appropriate technical, physical and organisational measures to safeguard and keep your personal data confidential, for example, by using contracts with appropriate confidentiality, data protection and security terms in our arrangements with third parties. Ahantaman Community Bank PLC has implemented information security and data privacy policies, including incident management and reporting procedures, rules and technical measures to protect personal data and to comply with legal and regulatory requirements. We train and require staff who access your personal data to comply with our data privacy and security standards. We require our service providers, or other third parties we engage with and to whom we disclose your personal data to implement similar confidentiality, data privacy and security standards and measures when they handle, access or process your personal data.

Face data is subject to appropriate technical and organizational safeguards, including access controls, secure transmission and storage, role-based access, audit logging and monitoring, vulnerability assessment and security testing, and secure backup and recovery measures, as applicable. Access is limited to authorized personnel and systems with a legitimate business, security, or regulatory requirement.

For the purposes described in this privacy notice, we keep your personal data for business operational or legal reasons while you engage with us and may retain your personal data for a period of time afterwards, depending on the type of personal data, in accordance with our data retention policy standards and as required by applicable law and regulations. We will delete, anonymise, destroy and/or stop using personal data when we no longer need it.

Face data collected through the mobile application will be retained for five years in accordance with Section 32(3) of the Anti-Money Laundering Act and Ahantaman Community Bank PLC’s approved data retention requirements, unless a longer period is required by applicable law, regulation, an ongoing investigation, dispute, or other legitimate legal or regulatory requirement. At the end of the applicable retention period, face data will be securely deleted or destroyed from active systems and, where applicable, associated storage and backup environments in accordance with established data disposal procedures.

We respect your personal data, and you have the following rights about how we use your information:

• Your right to access your datayou have the right to check whether we hold personal data about you, and you can ask us for a copy of such data and information on how we have used it.
• Your right to correct your dataif your personal details have changed, or you believe we have incorrect or out-of-date information about you, you can ask us to update it.
• Your right to delete your datayou can ask us to delete your personal data. However, we may need certain personal details to provide our products and services to you.
• Your right to restrict or object to processingyou can ask us to stop using your data or change how we use it. However, we may need certain personal details to engage with you or provide our products and services to you.
• Your right to object to automated decision makingyou can ask us to review a decision made solely by automated processing if it negatively impacts you.
• Your right to data portabilityyou can ask us to provide your personal data to another organisation in a format that can be easily read by machines.
• Your right not to provide or change or withdraw consentwe may from time to time ask for your consent to process your personal data. You can choose not to provide such consent or let us know at any time if you change your mind about the consent already provided. However, we may not be able to provide our products and services or engage with you without certain personal data.
• Your right to withdraw from direct marketingyou can withdraw your consent and tell us to stop sending you marketing emails or invitations to surveys at any time.

We will respond to requests to exercise your personal data rights in line with applicable law. We may ask you to verify your identity before processing your request. If you have any questions about your rights, please contact us using the details below.

The following Ahantaman Community Bank PLC acts as the data controller of your personal data.

Ahantaman Community Bank PLC

If you have any questions about this privacy notice or would like to exercise any of your personal data protection rights, you may contact our Data Privacy Officer at:

If you have any concerns or complaints about how we’re using your personal data, please talk to us. You can contact your branch or your Relationship Manager or get in touch with our Data Privacy Supervisor. You can also contact the Data Protection Commission of Ghana (DPC), for further assistance. You can find their details at dataprotection.org.gh.

Please see our separate Cookie Policy.

There may be specific terms and conditions in our banking and product agreements that govern the collection, use and disclosure of your personal data. Such other terms and conditions must be read in conjunction with this privacy notice.