Using your personal information
How we use your personal information
Please read this privacy notice to understand how we use and protect the information you provide to us.
Your information will be held by The Co-operative Bank p.l.c., also trading as smile, Britannia and Platform (and known as “the Bank”).
Data protection law and how it protects you
Data protection law requires us to manage all personal information in accordance with the data protection principles.In particular, we are required to process your personal information fairly and lawfully. This means you are entitled to know how we intend to use any information you provide. You can then choose whether you want to give it to us so we can provide the product or service you require.
1. Where we obtain the information
Your personal information will be held securely by the Bank so we can (either now or in the future) manage your relationship with us. This will include information you provided when you apply to us, and any additional information provided by you or others in various ways, including:
1.1. Your name, address, email address, telephone number and other contact information;
1.2. Your resume or CV, cover letter, previous and/or relevant work experience or other experience, education, memberships or other information you provide to us in support of an application and/or the application and recruitment process;
1.3. Information from interviews and phone-screenings and assessment processes you may have, if any;
1.4. Details of the type of employment you are or may be looking for, current and/or desired salary, and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences;
1.5. Details of how you heard about the position you are applying for;
1.6. Any sensitive (known as “Special Categories”) and/or demographic information obtained during the application or recruitment process such as gender, information about your nationality, medical or health information and/or your racial or ethnic origin;
1.7. Reference information and/or information received from background checks (where applicable), including information provided by third parties, internal references; and/or
1.8. Information relating to any previous applications you may have made to the Bank and/or any previous employment history with the bank.
We will not retain your personal information for longer than is necessary for the maintenance of your employment, or for legal or regulatory requirements. The Bank retains personal data relating to employees, after the end of the employment term, for a maximum of 7 years to meet our legal requirements. If you have any questions relating to the retention periods applied to your data please contact the Data Protection Officer at the following email address firstname.lastname@example.org
2. The personal information we collect and process
The Bank will only gather and process the relevant type and amount of personal information required, allowing us to help you recruit and then manage your employment with us.
The categories of personal information that we collect (or create on your behalf) are:
Some examples of the information in this category
· Residential address*
· Home telephone number
· Mobile telephone number
· Correspondence addresses
· Video Recordings
· Voice Recordings
3. How we use your information
We will use the personal information we hold about you for the following administrative activities:
How we use your information
Why we use your information
· Managing your employment application process with the organisation
· Our legitimate interests
· Your consent
By processing this information it enables us to manage your application in the efficient way you expect.
Your information will also be used for other purposes for which you give your specific permission, or, in very limited circumstances, when required by law.
4. When we will share your information
We will treat your personal information as private and confidential but will disclose it outside the Bank if:
4.1. Allowed by this agreement;
4.2. You consent;
4.3. Needed by sub-contractors to help us manage your records;
4.4. The law, regulatory bodies or the public interest permits or requires it;
4.5. Needed by organisations who provide us with a service, on the understanding they keep your information secure and confidential, unless you tell us not to;
We will always ensure your information remains safe and secure. Please go to co-operativebank.co.uk/global/thirdparties to see our HR supplier register.
5. Individual Rights
Right to be informed – you have the right to be informed about what we do with the data we have about you.
Right to access – you have the right to access personal data and supplementary information that is held about you by the Bank.
Right to rectification – you are entitled to have your personal data rectified if it is inaccurate or incomplete.
Right to erasure–you have the right to request the removal or deletion of your personal data (also known as “right to be forgotten”), where there is no compelling reason for the Bank to continue processing this data. The Bank can refuse your request where there is a legal obligation to hold the information.This will be further explained to you upon making a request.
Right to restrict processing– you have the right to restrict the processing of your personal data in the following circumstances (i) where you contest the accuracy of the personal data. The Bank will restrict the processing until you have verified the accuracy of the personal data (ii) where you have objected to the processing, and until the Bank has considered the legitimate grounds to override the processing. (iii) when processing is unlawful. (iv) where the Bank no longer needs the personal data but you require the data to establish, exercise or defend a legal claim.
Right to data portability– this right allows you to move copy or transfer your personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.
Right to object– you have the right to object to processing for direct marketing (including profiling) purposes.The Bank can refuse this right where there is a legitimate interest for processing your personal data.This will be further explained to you upon making a request.
Rights related to automated decision making including profiling– you have the right to object to automated decision making without any human involvement, and to the profiling of your personal data.
To invoke any of these rights contact
6. Legitimate Interest Tests
As an essential part of our business, the Bankcollects, holds and manages (“processes”) data relating to our employees. The data protection regulation recognises in certain circumstances, processing may be deemed “necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection”.
To validate a specific purpose for data processing is indeed legitimate; the Bank will conduct a legitimate interests test. This will serve to balance our rights to process the data against the data protection rights of the affected individuals.
In making the decision whether or not legitimate interests may apply in each circumstance, we will ensure the balance of rights always favours the individual customer, and the processing will not cause the individual unwarranted harm by means of discrimination, damage to reputation, financial loss, and loss of confidentiality or other significant economic or social disadvantage.
7. Recording phone calls
We will monitor or record phone calls with you in case we need to check we have carried out your instructions correctly, to resolve queries or issues, for regulatory purposes, to help improve our quality of service, and to help detect or prevent fraud or other crimes.
Conversations will also be monitored for staff training purposes.
8. Obtaining a copy of your information
Under data protection law, you have the right to access the personal information we hold about you.Additionally, you have the right to restrict and object to certain data processing.
To request access to the information, and/or to inform us about a data restriction or objection, please contact the Data protection Officer at the address below or via email email@example.com
The Data Protection Officer
The Co-operative Bank plc
1 Balloon Street
9. Your right to rectify and erase data we hold about you
It is important the information we hold about you is accurate and up to date at all times, as holding incorrect information can have an impact on what the bank shares with third parties such as the taxation authorities.
If you believe we are holding any information relating to you which is incorrect please contact us to let us know what is wrong, and we will work with you to put it right.
10. How we protect your information
We are committed to taking appropriate technical, physical and organisational measures to protect colleague personal information against unauthorised access, unlawful processing, accidental loss or damage, and unauthorised destruction. We also take appropriate measures to ensure the information disclosed to us is kept secure, accurate and up-to-date and kept only for so long as necessary for the purposes which it is used.
We limit access to our internal systems which hold personal information to a selected group of authorised users who are given access to such systems through the use of a unique identifier and password.Access to personal information is limited to and provided to individuals for the purpose of performing their work duties.
11. Changes to privacy notice
We will update this notice to reflect changes to our information practices.If we make any material changes we will notify you by means of a notice on our intranet site prior to the change becoming effective.We encourage you to periodically review this page for the latest information on our privacy practices.
12. Contact details for the Bank Data Protection Officer
If you wish to contact the Data Protection Officer in relation to any questions or confidential queries about this privacy notice or the information we hold and process about you, please email firstname.lastname@example.org or write to us at:
The Data Protection Officer
The Co-operative Bank plc
PO Box 101
1 Balloon Street
13. Contact details for the Information Commissioner’s Office
If you wish to contact the Information Commissioner for advice or to complain about the way you believe your information is used, please find their address and website below.
The Information Commissioner’s Office