1. What does the Beneficiary Name Display Service (SANB) represent?
1. What does the Beneficiary Name Display Service (SANB) represent?
Banca Transilvania S.A. (“BT”, “bank”, “we”) together with other banks in Romania (“participating banks”) offers the Beneficiary Name Display Service (SANB), to prevent frauds to which their individual clients may be exposed. .
This service is available to clients of participating banks who initiate payments to accounts opened at another participating bank within payment/internet banking applications. SANB involves truncated display, to the payment initiator - a client of a participating bank - of the truncated name of the payment beneficiary - a client of another participating bank. Details about SANB can be found on the BT website here.
SANB can only operate if the participating banks exchange the information necessary to display the truncated name of the payment beneficiary. When directly or indirectly identifying a natural person, this information is personal data.
Since you are a BT client (participating bank), your personal data is processed within SANB. Thus, you are a data subject and we inform you through this notice about the details of this processing.
For the avoidance of any doubt, all the information in this information note refers to your data processed for the provision of the SANB service. The processing of the data belonging to you carried out by Banca Transilvania, as an independent operator, in the context of the BT client status that you have, is subject to the provisionsGeneral information notes regarding the processing and protection of personal data belonging to BT Clients.
2. Operators of personal data
2. Operators of personal data
The exchange of information necessary for the operation of SANB will be carried out through a common database, which will be managed by the Fund Transfer and Settlement Society (“Transfond”).
The participating banks and Transfond will process the data of the data subjects as joint controllers, as this term is defined in the General Data Protection Regulation (“GDPR”) and have established through an agreement their responsibilities regarding the fulfillment of the obligations imposed by the GDPR, especially those related to the confidentiality and security of personal data, as well as their role and relationship to these persons.
The list of banks participating in SANB may undergo changes, by the joining or, as the case may be, withdrawal from SANB of some of them. The updated up-to-date list of all banks participating in SANB can be found here.
3. The purpose of processing, the categories of processed data and their recipients
3. The purpose of processing, the categories of processed data and their recipients
The exchange of personal data is carried out by the associated operators exclusively for the purpose of displaying the truncated name of the beneficiary for customers of participating banks, for fraud prevention.
Categories of personal data processed are the first name(s) (one or more, as applicable), the initial of your family name, and the IBAN code of the account(s) opened at a participating bank.
As a participating bank in SANB, BT sends to Transfond your first name and the initial of your last name, along with the IBAN code of the account/accounts opened at BT.
In the case of your data related to BT accounts, we are the operator who collects this data and transmits it to the associated operator Transfond, at the level of which the data will be stored. Subsequently, if a client of a participating bank initiates a payment to an account of yours opened at BT, this data concerning you will become accessible to the participating bank from which the person initiates the payment and, implicitly, to the client of that initiating bank (after the client themselves enters the IBAN code of your BT account in the payment application). They will be shown your first name (in full) and the initial of your last name, as they are recorded in BT's records, regardless of whether the payment will be completed or not.
At the same time, if you initiate a payment from a BT payment application/ internet banking/ an application of a third-party payment service provider, authorized as such, to the account of a client from another participating bank, the client's first name and the initial of their last name, as registered at that participating bank, will be displayed to you after you enter the IBAN code of the client's account at that participating bank.
4. The legal basis for processing personal data and the consequences of refusing to have them processed
4. The legal basis for processing personal data and the consequences of refusing to have them processed
The legal basis for processing your personal data is the legitimate interest of the participating banks to provide a fraud prevention tool in the case of interbank payments initiated through payment/internet banking applications.
If you refuse the processing of your personal data for SANB, a client of a participating bank who wishes to initiate a payment to you via internet banking will not see your truncated name displayed, and thus, in case they make a mistake in one character of your IBAN code, it is possible that the amount intended for you will reach another person.
5. The period of storage of personal data in the context of SANB
5. The period of storage of personal data in the context of SANB
Your personal data related to SANB will be stored in the Transfond database, and will thus be available - as appropriate - to the other participating banks and their clients who initiate payments, as long as you are a BT client and Banca Transilvania is a participant in SANB.
6. The rights that are guaranteed to you
6. The rights that are guaranteed to you
Regarding the processing of your personal data within SANB, you are guaranteed the exercise of the rights provided by the GDPR. You can exercise these rights with any of the associated operators, at the contact details of their data protection officers (DPO) found in the Privacy Policies on each of their websites. As a rule, each operator will respond to requests by which data subjects exercise rights related to the processing for which that operator is responsible, but, if necessary, the associated operators, through Transfond, will inform each other and provide the necessary information to be able to respond to any requests from the data subjects.
The rights guaranteed to you are: the right to information (we fulfill our obligation to inform you through this information note), the right to object to the processing of your data by SANB, the right to access processed data, the right to rectify data, the right to delete data, the right to restrict processing, the right to data portability, the right to address a complaint to the National Supervisory Authority for Personal Data Processing (ANSPDCP).
