Public Statement
of Data Processing and Registrable Particular.

pursuant to § 4 e of the German Data Protection Act (Bundesdatenschutzgesetz, abbr. BDSG)


The German Data Protection Act stipulates in § 4 g that the data protection officer is required to make the following details as specified in § 4 e available in an appropriate manner to the public:


1. Name of the data controlling company:

  • Landesbank Baden-Württemberg
  • Baden-Württembergische Bank (BW-Bank),
    Unselbstständige Anstalt der Landesbank Baden-Württemberg

2. Members of the Board of Managing Directors:

  • Hans-Jörg Vetter, Chairman
  • Rainer Neske (Chairman from November 1, 2016)
  • Michael Horn, Deputy Chairman
  • Karl Manfred Lochner
  • Ingo Mandt
  • Alexander Freiherr von Uslar-Gleichen
  • Volker Wirth

3. Head of Data Processing:


Michael Spiegel, IT/Organisation


4. Address of the data controlling company:


Landesbank Baden-Württemberg
Am Hauptbahnhof 2
D-70173 Stuttgart


5. Purpose and objective of data collection, processing and use:


The bank’s line of products spans all traditional financial services ranging from retail deposit and lending operations to commercial and corporate financing. Bank supports its principally small and medium-sized corporate customers in every stage of development by providing the services they require. Furthermore, the bank’s customer services also includes offering its high net-worth customers a comprehensive range of portfolio management services and supporting its institutional customers in the area of asset management. International business as well as money, securities and foreign exchange trading also form part of its service spectrum. Business with public sector customers as well as real estate brokerage and financing round off its array of services.

Subsidiaries and companies in which an equity interest is held further augment the services. The spectrum extends from leasing and factoring as well as managing specialised securities funds to granting venture capital and offering equity financing. It also includes providing special financial services to local authorities and offering a comprehensive range of services around real estate.

In cooperation with its partners within the Savings Banks Financial Group, the bank provides the full range of financial services including building society savings and insurances.

Personal data is collected, processed, stored and used to achieve the aforementioned objectives. Personal data is predominantly:

  • personal details (e.g. name, address, date of birth, marital status and profession, preferred leisure activities)
  • income data (wage, salary, secondary activities or spare-time work)
  • data on assets and financial situation (real estate, securities, account balance/s)
  • contract data (loan or credit agreements, insurances policies)
  • purpose and expected turnover of existing bank accounts
  • origin of assets
  • information on the sector business partners are engaged in.

In addition, there is video surveillance to secure evidence in case of bank robbery or fraudulent acts or to provide proof of cash withdrawals at ATMs. Furthermore, digitised recordings are made of telephone calls with traders for the purpose of documentation and evidence, as well as of telephone banking calls.


6. Description of the groups of data subjects and the respective data or data categories:


Personal data is predominantly collected, processed, stored and used with regard to the following groups of persons:

  • customer data (address data, contract data, data on banking services)
  • interested persons or prospective customers (product interests, address data)
  • data of employees, data of job applicants, data of intermediaries, brokers and agencies
  • (personnel data for HR administration and management)
  • tenants, business partners, intermediaries, agents and brokers (address data, accounting and
  • services data)
  • suppliers (address and functional data)

7. Recipients or categories of recipients to whom data may be disclosed

  • public authorities that receive the data in compliance with statutory requirements (e.g. social insurance institutions)
  • internal units that are involved in performing the respective business processes (e.g. HR administration, giro and payment transactions, sections involved in the lending
  • operations, marketing, sales, auditing, IT/ORG.)
  • external contractors (service providers) in accordance with § 11 BDSG
  • other external bodies such as subsidiaries or affiliated companies in connection with intermediary services

8. Standard periods for deletion


Various record retention obligations and periods have been laid down by law. Upon expiry of these periods, the respective data is deleted as a matter of routine if it is no longer required for the performance of the contract (e.g. current account agreement, loan or credit agreement, land charge certificate, etc.).

Where data is not affected by these regulations, it will be deleted once the purpose and objective specified under No. 5 have ceased to exist.


9. Planned data transfer to third states


Data will be transferred to third states where it is necessary to fulfil a contract, to satisfy a quasi-contractual relation as well as to give advice and service to the person concerned. The bank is obliged to report income and/or customer data in the USA in connection with transactions involving securities of US issuers.

Basis: In addition to the “Agreement between the Federal Republic of Germany and the United States of America to avoid double taxation and to prevent tax evasion” (Double Taxation Agreement, DBA USA), the bank has signed an agreement (Qualified Intermediary Agreement) with the US Internal Revenue Service so that transactions involving securities of US issuers may be executed in future as well. The bank is bound by this agreement to additional documentation and reporting requirements.

Recipient: US Internal Revenue Service Name, address data, income data and data on reflow of capital from securities

Form of Transfer: "US data subjects" (i.e. all persons who are subject to the US income tax law), "transparent legal entities" (i.e. all bodies of persons who themselves are non-tax subjects) as well as all trust and escrow accounts are subject to separate, individual reports. All affected customers will receive a copy of the report.

Whereas income of all other securities account holders will be transferred as summary reports in an anonymised form.


Landesbank Baden-Württemberg


Landesbank Baden-Württemberg
Am Hauptbahnhof 2
D-70173 Stuttgart

Ludger Viktora
Data Protection Officer
Tel.: +49 711 127-73495
Fax: +49 711 127-76752