OakNorth Bank plc (“We”, “us”, “our” or “Bank”) is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority (Financial Services Register No. 629564). Registered in England No. 08595042. Registered Office: 57 Broadwick Street, London, W1F 9QS. References to “You” or “Your” is to the employee, job applicant, intern, former employees, dependents, consultants and temporary agency workers of the Bank. You agree the Bank shall collect and process Your personal data for legitimate business purposes to administer Your employment or our contractual relationship with You and to run Bank’s business. The Bank may collect, use and transfer Your personal data through automated and/or paper based data processing systems in order to provide certain services or benefits relating, but not limited, to: job offer, payroll, health, pension, life cover, immigration, training, computer access, site access, etc. as relevant to Your (offer of) employment.

You can contact our People Operations team:

  1. By writing:
    OakNorth Bank plc
    1st Floor, Alexandra Buildings
    28 Queen Street
    Manchester
    M2 5HX
  2. By calling:
    Name Title E-mail
    Adria Linder Head of People Operations adria.linder@oaknorth.com
    Farzana Choudhary People Operations Associate farzana.choudhary@oaknorth.com

You can contact our Data Protection Officer directly by emailing: DPO@oaknorth.com

 

1. Purposes for which the personal data will be processed:

Before we provide You with certain services or benefits, we shall collect and process Your personal data to conduct and/or facilitate (a) workforce planning, recruitment and staffing; (b) workforce administration, payroll, compensation and benefit programs; (c) performance management, learning and development; (d) advancement and succession planning; (e) legal compliance requests, including compliance with government authority requests for information, liens, garnishments and tax compliance; (f) workplace management, such as travel and expense programs and internal health and safety programs; (g) internal reporting; (h) audits; (i) programs to protect the Bank, its workforce and the public against injury, theft, legal liability, fraud or abuse; and (j) other legal and customary business as relevant. For this, we shall undertake a full background check wherein we will verify the information supplied by You through checks such as 1) Adverse Financial and Criminal Records (including County Court Judgements (CCJs), bankruptcies, Individual Voluntary Arrangements (IVAs), detrimental data resulting from falsification of address, 2) Identity3) DVLA (Driver and Vehicle Licensing Agency), 4) Media, 5) Sanctions6) Statutory Excuse7) Criminal Records8) Occupational History, and 9) Individual References (Professional, Educational, Personal). Notwithstanding the initial checks, You shall also agree to ongoing monitoring of Your background and an annual Adverse Financial and Criminal Records check. We may also ask You to provide physical forms of identity verification including Your passport and driver’s licence as relevant.

If You would like access to the information we receive from any of our vendors or any other source, please contact the People Operations department in order to make a Subject Access Request (SAR). We accept no responsibility or liability for the actions of any of our vendors which act as separate and independent controllers. Any information which is controlled by them and used for the purpose of fraud prevention/credit checks are not governed by our Privacy Policy.

Furthermore, we shall process Your personal data for and on the following purposes/grounds:

Category of Personal Data Purpose for Processing Processing Grounds
contact information

financial information

educational and training information

recruitment and performance related information

identity information

historical address information

tax residency information

 

 

employment status information

online identifier information

risk and/or fraud information

operating, maintaining and administering Your (offer of) employment and/or our business; contract
providing You with the services and benefits related to employment; contract
preventing or detecting money laundering, financial crimes, fraud or any other illegal activity, carrying out electronic verification checks including criminal records, Politically Exposed Person (PEPs), media, and sanctions checks; legal obligation

legitimate interest

contact information

financial information

identity information

historical address information

tax residency information

employment status information online identifier information

payroll and payment or benefits related information

information needed for compliance and risk management

risk and/or fraud information

internal reporting (for business operation purposes) and external reporting (for compliance with any legal and/or regulatory obligations); legitimate interest

legal obligation

our confidential research and analysis; legitimate interest
complying with any other legal and/or regulatory requirements including legitimate requests for information from law enforcement or regulatory bodies/agencies; legal obligation

legitimate interest

contact information

financial information

identity information

historical address information

tax residency information

employment status information

risk and/or fraud information

general record keeping requirements as stipulated by the Regulatory Authority (Financial Conduct Authority (FCA) & Prudential Regulation Authority (PRA)); legal obligation
contact information

identity information

employment status information

employment verification; legitimate interest
cv, salary data, first and last name, employer, title, e-mail address, telephone numbers, LinkedIn address, location, introductory (referral source), years in current role talent sourcing, talent pool management, managing contact database, maintaining and building an internal recruitment function. legal obligation

legitimate interest

 

Glossary of Categories of Personal Data
Category of Personal Data Included Information
contact information postal address, email address, telephone number(s), family and emergency contact details
identity information title, name, nationality, gender or gender identification, date of birth, photograph, signature, electoral roll data, passport
historical address information minimum five years of address history, immigration, right to work and residence status
educational and training information educational awards, certificates and licenses, vocational records and in-house training attendance
employment status information career history / resume, employed, self-employed, student, retired, other, years of service, work location, employment ID, work record, vacation absences and contract data
recruitment and performance related data objectives, ratings, comments, feedback results, career history, work equipment, career and succession planning, skills and competencies and other work-related qualifications
information needed for compliance and risk management disciplinary records, background check reports and security data
payroll and payment or benefits related information salary, insurance information, dependents, government identifier or tax numbers, bank account details and employment related benefits information
financial information nominated bank account number and sort code, existing ISA account(s) details
tax residency information national insurance number, foreign tax identification number(s), citizenship(s)
risk and/or fraud information information held by fraud prevention and risk management agencies which may include information about Your identity, activities, credit information, allegations or criminal convictions
online identifier information IP address, cookies
directorship information directorship role of business
shareholding information beneficial ownership of business

 

We will retain Your personal data, that You supply as a part of Your onboarding and through Your other interactions with us (including identification data, product data, email correspondence, and transactional information) both on paper and on computer, and/or other electronic devices for 6 years after the termination of our employment relationship to comply with legal and regulatory obligations (including any possible fraud, financial crime and complaints investigations), to retain a reference and audit trail of any discussions, and to preserve a record of employment history to facilitate a streamlined employment journey for any future new employment applications. If You apply for any vacancy, but do not join and/or employment is not being offered to You for any reason, the same personal data will be retained for at least 3 years after the closing date of Your application for the same reasons. Based on our recruitment policy a subset of your data limited to: CV (only if you provided), Salary Data (only if you provided), First Name, Last Name, OakNorth contact, i.e., whether we approached you about a role and your response, Prospective Job (if relevant), Current Employer, Current Title, E-mail address (personal and work as applicable), All Listed Telephone Numbers (as available), LinkedIn address (as applicable), Current Location, Years Spent in Current Role, Any Other Notes (which are held in strict confidence and only obtained through e-mail conversations), and Interview Schedules, will be kept in our files for not more than 20 years. Interview notes and related feedback associated with unsuccessful applications will be destroyed 6 months from their date of creation. However, if a process was partially successful and the feedback anywhere from average to excellent, these notes and feedback will be retained for a period of 2 years. Furthermore, your data may be shared with our sister company, ACORN machine (UK) Ltd. and ACORN’s group companies in Singapore and the U.S. as a part of our general recruiting practice. As a result, you may equally be considered for roles in OakNorth or ACORN.

We will retain records in accordance with our retention policy and to comply with regulatory requirements. This includes retaining backups of our systems infrastructure for disaster recovery purposes and for the protection of data and collecting temporary logs of online applications to record Your application progress and provide support in the case of any application issues.

We may monitor or record business calls, emails, text messages or other communications related to business in accordance with applicable laws. Such recording or monitoring may take place for business purposes such as quality control and training, prevention of unauthorised use of our telecommunication systems and website, ensuring effective systems operation, prevention or detection of crime, and protection of confidential information relating to the Bank, including personal data of any user connected with their account(s). Call recordings may be retained for 6 months from the day of the call, or 3 years in case the call recording is part of a complaint which has been raised and the retention of which may be necessary to comply with any legal and/or regulatory requirements.

We may process Your personal data from business cards where the information was captured in a personal networking capacity as part of our business operations, relying on legitimate interest. We will ensure the processing is fair, proportionate and in line with normal business practice.

We may use 3rd party processors for our confidential research and analysis and/ or for payroll, background verification etc.

When You visit our website, we will set essential cookies on Your device, but request Your consent to set non-essential cookies. You can find out more about how we use cookies in ourCookie Policy. However, please note that we use Google Analytics, a third-party web analysis service provided by Google Inc., which uses performance cookies and targeting cookies. The information generated by these cookies about Your use of the Website (including Your IP address), will be transmitted to and stored by Google Inc. on servers in the United States. Google will use the information collected for the purpose of evaluating Your use of our Website on our behalf, compiling reports on website activity and providing other services relating to activity and internet usage to us. Google will not associate Your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on Your browser as described above. Furthermore, You can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB. This creates an opt-out cookie which prevents the further processing of Your data. For more information about Google Analytics cookies, please see Google’s help pages and privacy policy. If You prevent these cookies, we cannot guarantee how the Website will perform for You.

We shall inform You by way of a dedicated email if our privacy policy has changed because of an update in the law or if there are changes to the nature of the processing of Your personal data. We will not email You when we make minor changes (such as to correct typographical errors, or to add information about other services which do not affect the processing of personal data), but we shall make the updated policy available on our website at all times.

2. Data transfers

We will take appropriate security measures to ensure that Your personal data is protected and secured in accordance with the relevant data protection laws, including the General Data Protection Regulation (GDPR). We will only disclose information about You to third party data processors who shall process Your personal data on our behalf (like our service provider and affiliate entity, OakNorth Global Private Limited in India). We may also disclose information about You if we are required by law or regulation to do so. We shall ensure that our data processors shall process Your data based on our instructions and have appropriate data security measures to protect Your personal data.

In some cases, we may need to transfer Your information to third parties overseas including to our affiliate entity: OakNorth Global Private Limited in India, i.e. outside the European Economic Area. However, we will ensure that adequate procedures and safeguards such as the European Commission Model Contract Clauses as an example, are in place to protect Your personal data at all times and that any affiliates and third parties are contractually obligated to provide an adequate level of data protection in accordance with the EU data protection laws.

The UK government has and is agreeing to inter-governmental agreements to share tax information. We ask for details of Your tax residency and in some cases tax reference numbers to enable us to comply with the related UK legislation. If You are a US person (US passport or US Born or US Registered address or US Taxpayer) we may be obliged to provide any required details about You and Your account with us to comply with the Foreign Account Tax Compliance Act (FATCA).

If we believe that we have tax obligations in other countries, we may disclose information about the Bank directly to those tax authorities or to HM Revenue & Customs, who may share that information with other tax authorities. We may disclose information we hold about You directly to those tax authorities or to HM Revenue & Customs, who may also share that information with other tax authorities.

3. Impacts of processing

If we determine that You pose a fraud or financial crime risk (which may be based on information provided to us by a fraud prevention agency), we may refuse to provide the employment You have requested, or we may terminate Your employment with the Bank. A record of any fraud or money laundering risk will be retained by us for so long as is permitted by law and may result in others refusing to provide employment to You.

If false or inaccurate information is provided and fraud is identified or suspected, we may pass information to financial and other organisations involved in fraud prevention to protect us and our customers from theft and fraud.

Law enforcement agencies may also access and use this information to detect, investigate and prevent crime. We may provide the law enforcement agencies with information about You which we consider relevant to assist with any investigation of criminal activity.

4. Your rights

Your personal data is protected by legal rights (where applicable), and may include:

  1. The right to be informed
    • The right to be informed encompasses our obligation to provide ‘fair processing information’ through a privacy notice. It emphasises the need for transparency over how we use personal data.
  2. The right of access
    • You have the right to access Your personal data and supplementary information. The right of access allows You to be aware of and verify the lawfulness of the processing of Your personal data. The right of access allows You to submit a Subject Access Request (SAR) for a copy of the personal data that we hold about You.
  3. The right to rectification
    • The GDPR gives You the right to have personal data rectified if it is inaccurate or incomplete.
  4. The right to erasure
    • The right to erasure is also known as ‘the right to be forgotten’. The broad principle underpinning this right is to enable You to request the deletion or removal of personal data where there is no compelling reason for its continued processing. The right to erasure does not provide an absolute ‘right to be forgotten’. You have a right to have personal data erased and to prevent processing in specific circumstances, such as:
      1. Where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed.
      2. When You withdraw consent where consent is based on the points below, without affecting the lawfulness of processing based on consent before such withdrawal.
        1. Where You have given consent to the processing of Your personal data for one or more specific purposes; or
        2. Where You have given explicit consent to the processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation for one or more specified purposes, except where Union or UK law provide that the prohibition may not be lifted by the data subject.

        For example, if You provided consent to direct email marketing, You have the right to withdraw this consent.

      3. When You object to the processing and there is no overriding legitimate interest for continuing the processing.
      4. The personal data was unlawfully processed.
      5. The personal data has to be erased in order to comply with a legal obligation.
      6. The personal data is processed in relation to the offer of information society services to a child.
  5. The right to restrict processing
    • You have the right to ‘block’ or suppress processing of personal data, which will make it restricted, and permit us to store the personal data, but not to process it further. We would retain just enough information about You to ensure that the restriction is respected in the future. We will be required to restrict the processing of Your personal data in the following circumstances:
      1. Where You contest the accuracy of Your personal data. We will restrict the processing until we have verified the accuracy of the personal data.
      2. Where You have objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and we are considering whether our legitimate grounds override Your individual rights.
      3. When processing is unlawful and You oppose erasure and request restriction instead.
      4. If we no longer need the personal data but You require the data to establish, exercise or defend a legal claim.
    • We must inform You when we decide to lift a restriction on processing.
  6. The right to data portability
    • The right to data portability allows You to obtain and reuse Your personal data for Your own purposes across different services. It allows You to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. The right to data portability only applies to personal data You provided to us, where the processing is based on Your consent or for the performance of a contract; and when processing is carried out by automated means.
  7. The right to object
    • You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics. You must have an objection on “grounds relating to Your particular situation” if processing is based on performance of a legal task, our legitimate interests, or research purposes.
  8. The right in relation to automated decision making and profiling
    • Article 22 of the GDPR has additional rules to protect You if we are carrying out solely automated decision-making that has legal or similarly significant effects on You. We will only carry out this type of decision-making where the decision is: necessary for the entry into or performance of a contract, authorised by Union or UK law applicable to us, or based on Your explicit consent.

For more information or to exercise Your data protection rights, please contact People Operations or the Bank’s DPO using the contact details above.

If You have a complaint about how we have used your information, You should contact our Business Desk using the contact details above so that we can assist You in dealing with Your complaint, however, You also have the right to complain to the Information Commissioner’s Office (ICO), which regulates the processing of personal data. Information on how to report a complaint to the ICO can be found on their website; www.ico.org.uk or by calling them on 0303 123 1113.