Job Applicant Privacy Notice

1. Purpose of this document

If you wish to apply for a job opening at The Bank of London Group Limited or Oplyse Holdings Limited (collectively referred as “Bank of London”), this notice informs you that we will process any personal data you provide in a data controller role. This means that we are responsible for deciding why and how we process your personal information, and for how long.

We are committed to protect it in accordance to all data protection laws applicable in the countries where our members of staff are located (currently United Kingdom and Lithuania).

This privacy notice describes how we collect and use personal information about you during the job candidate selection process, in accordance with the UK and EU General Data Protection Regulation (UK GDPR and EU GDPR).

It is produced to comply with our transparency obligations towards you when processing your personal information for the purpose of recruitment.

2. Scope

This privacy notice applies to any individual who applies to a job opening at the Bank of London. We strongly encourage you to familiarise with this notice and, since it may be updated at any time when required, we encourage you to visit this page often.

3. Data protection principles

We will process your personal information according to the data protection principles described in the GDPR, requiring that the personal information we hold about you must be:

  1. Used lawfully, fairly and in a transparent way;
  2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
  3. Relevant to the purposes we have told you about and limited only to those purposes;
  4. Accurate and, where possible, kept up to date;
  5. Kept only as long as necessary for the purposes we have told you about;
  6. Kept and processed securely.

4. How we collect your personal data

We collect personal data about applicants through the application and recruitment process, either directly from you or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including the former employers you disclose, credit reference agencies or other background check agencies.

5. Type of information we process about you

Personal data, or personal information, is intended as any information about an individual from which that person can be identified. It does not include data where the person's identity has been removed (anonymous data).

Certain types of personal data are considered sensitive by the law and require a higher level of protection, such as information about a person's health, sexual orientation, race or ethnicity or criminal convictions.

We may collect, store, and process the following categories of personal data:

  • personal details such as name, address (including proof of address), date and place of birth, telephone number(s);
  • work history/job data: previous employers, positions, dates;
  • curriculum vitae or resumes and any other documents you elect to provide as evidence of your qualifications and work experience
  • remuneration: basic salary, benefit entitlements, bonuses;
  • education and work history including professional qualifications, skills and/or memberships;
  • references to include regulated references where necessary (this could include absence information received from referees);
  • nationality/visa/right to work information (e.g., passport/driving licence/national insurance numbers/birth certificate/evidence of name or gender change);
  • results of pre-employment screening checks (e.g., credit history and criminal records checks where permitted by law);
  • notes from interviews with our personnel;
  • images from onsite CCTV (if you attend an interview in our premises) and audio recordings of telephone interviews (if relevant).

We may also generate the following information about you:

  • application data including information about your individual performance in any interview or assessments that we ask you to carry out;
  • records of correspondence and other communications between us, including email,
    instant messages, and social media communications;
  • investigations data, e.g. due diligence checks, fraud, sanctions and anti-money laundering
    checks, external intelligence reports;
  • information we collect or infer from publicly available sources such as LinkedIn and other social media platforms.

During the process we may also capture some special category data about you in order to plan for making reasonable adjustments (e.g. details of any disabilities) and allow us to complete pre-employment checks.

In very limited and infrequent circumstances, we may approach you for your explicit consent to allow us to process certain sensitive personal data. If we do, we will provide you with full details of the personal data that we would like and the reason we need it, so that you can carefully consider whether you wish to consent.

If you fail to provide personal information

If you fail to provide certain information when requested, we may not be able to progress with your application.

6. Why we process your personal information

We will process your personal data for the purposes of progressing your application as required by law or regulatory requirements, so not all of the purposes for which we process your personal data will apply to you all of the time.

Most commonly, we will use your personal information for the following purposes:

  1. To pursue our legitimate interests (e.g., to assess your suitability for the role you are
    applying for; to respond to and defend our position in legal claims);
  2. To comply with a legal obligation (e.g. to verify your right to work in the country where the job you applied to is located);
  3. To pursue purposes is in the public interest (e.g. the purpose of preventing or detecting crime or for equal opportunity monitoring and/or reporting purposes).

7. How we make decisions about you

We do not use automated systems to help us make decisions about the outcome of your application. All our recruitment decisions in our organisation are taken by humans.

8. Sharing your personal information with third parties

We will share your personal data internally within our Group and with some external third parties providing services to us (e.g. Credit Reference Agencies).

All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.

In all cases, we will only share the information necessary for the stated purpose and no more than that.

9. Transferring your personal information outside the UK or the EU

We may transfer your personal information to third parties whose personnel and/or suppliers are located in countries outside the UK or EU for the purposes described in paragraph 6. When we do so, we ensure either that:

  • the receiving organisation is located in a country recognised by the UK and the EU to ensure an adequate level of protection of personal data (“adequate country”: see list HERE); or
  • the receiving organisation is contractually bound by us to ensure at least the same level of protection to your data that we provide when we process it.

10. Data security

We have implemented, and regularly test, appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal information to those employees, agents, contractors with a role in the recruitment process.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of personal data breach where we are legally required to do so.

11. Data retention

We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it.

To determine the appropriate retention period for personal data, we consider:

  • The amount, nature and sensitivity of the personal data.
  • The potential risk of harm from unauthorised use or disclosure of your personal data.
  • The purposes for which we process your personal data
  • The applicable legal requirements.

In the case of unsuccessful job applicants, we will retain the information provided for no longer than 12 months from the date our last communication (in most cases this being the notice of unsuccessful candidature) is sent.

This is for our legitimate interest to monitor the fairness of our recruitment process, to improve its  efficiency and effectiveness, to help us respond to queries or complaints, and to defend our position in case of legal claims.

For successful candidates offered and accepting a role in our firm, the recruitment data will be retained according to our Employee Privacy Notice.

12. Your rights over your personal information

You may have a number of rights in relation to the information that we hold about you. These rights include:

  • The right to access information we hold about you and to obtain information about how we process it;
  • In some circumstances, the right to withdraw your consent to our processing of your information, which you can do at any time. However note that we may continue to process your information if we have another legitimate reason for doing so;
  • In some circumstances, the right to receive certain information you have provided to us in an electronic format and / or request that we transmit it to a third party specified by you;
  • The right to request that we rectify your information if it’s inaccurate or incomplete;
  • In some circumstances, the right to request that we erase your information. However note that we may continue to retain your information if we’re entitled or required to retain it;
  • The right to object to, and to request that we restrict, our processing of your information in some circumstances. Again, note that there may be situations where you object to, or ask us to restrict, our processing of your information but we’re entitled to continue processing your information and/or to refuse that request.

You can exercise your rights by contacting us using the details set out in the Contact us section below.

You also have the right to complain to the data protection regulator in the country where you live or work, if you are dissatisfied by how we process your personal information and/or by how we processed your request to exercise your rights over your personal data.

13. Contact us

If you have any questions about this privacy notice, about how we handle your personal information that can’t be answered by reading this policy, or if you have a complaint in regard to how we use your information, please contact our DPO in writing at dpo@bankoflondon.com.

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