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As a bank, we make use of profiling. This entails that in certain situations we automatically assemble a profile using a set of your personal data. Below we explain why we do this, and when.


Fraud prevention

We have a great deal of knowledge and experience in the area of fraud prevention. Unfortunately, we are facing increasingly sophisticated forms of fraud. To identify the behaviour or indications that point to a specific form of fraud, we observe what happens when this form of fraud is committed. This allows us to create a profile that we use to identify certain activities and to allow further investigations. We can then take measures to prevent fraud as much as possible.

Fraud detection and payments

We carry out fraud detection activities in an effort to prevent clients and the bank from suffering potential losses as a result of fraud. We do this by creating a profile of the client who issues the payment instruction. We use the data from the time the client logs on to Online Banking and initiates the payment instruction, up to and including the time the payment is sent to the beneficiary's account. One of the purposes for which these profiles are used is to enable decisions to be taken quickly by automated means. This is necessary to prevent the immediate execution of potentially fraudulent transactions through Online Banking. It also gives us an opportunity to assess the transaction and, if necessary, contact you, the instructing party. These profiles are based on your personal characteristics and not on those of others. Here, personal characteristics refer to aspects such as internet traffic between you and ABN AMRO, and your transaction history - as the instructing party - with the beneficiaries to which you transfer money.

If you do not have a bank account with us and you receive money as a result of a payment instruction issued by one of our clients, the personal data relating to you - the beneficiary - which is recorded in the payment transaction will also be used for the purpose of fraud detection.

Unusual transactions

As a bank, we have to comply with the Act for the prevention of money laundering and the financing of terrorism and for the limitation of the use of cash (Wet tot voorkoming van het witwassen van geld en de financiering van terrorisme en tot beperking van het gebruik van contanten). We therefore pay particular attention to unusual transactions and to transactions that - by their nature - result in a relative high risk of money laundering. To do this, we need to create and maintain a risk profile of the client. If we suspect that a transaction is connected with money laundering or terrorist financing, we will report this to the authorities.

Client and product acceptance

How do we use profiling when you want to purchase a product? The following example explains how we do this. Imagine that you apply for a loan from us.

  1. We notify you in advance of the procedure we will follow to create a profile and what you can expect.
  2. We carry out a risk assessment. We do this for new clients and also for existing clients who want to buy additional products. We know from experience that certain characteristics can indicate whether you are able to repay a loan easily. These characteristics include whether you have a job or any debts. We assess these characteristics.
  3. Clients who are normally able to pay back a loan share a number of characteristics, as do clients who are normally unable to repay loans. Your characteristics are used as a basis for the creation of a profile.
  4. We compare your profile with our existing profiles. Finally, we assess how likely it is that you will not be able to repay the loan.

Direct marketing

We also use profiling to send you offers that are appropriate to you. For example, if you have a mortgage you will not receive any offers for mortgages from us. We attempt to identify your areas of interest, based on a number of characteristics. We then look at specific aspects, such as your age category and whether you already have any other products from us. You will only be selected for a relevant marketing campaign if you meet a specific profile. Obviously, we check the data protection rules to determine whether personal data may be used for that purpose. You may object to the creation of a personalised client profile for direct marketing purposes at any time.

If you do not have a contract with us, we determine whether direct marketing is permitted in specific situations on a case-by-case basis, and separately for each type of personal data and for each group.