How Nationwide uses your information
This privacy notice explains how Nationwide will use and protect your personal information when you apply for a role with us, in accordance with our obligations under data protection law.
Who collects and uses your information?
Under data protection law, an organisation that decides how the personal information that it collects and holds is used, is called a ‘data controller’. We call this use of personal information ‘processing’.
In certain circumstances, Nationwide Building Society has a number of subsidiary entities which may also be the data controller of your personal information.
What information does Nationwide collect and hold?
We collect and hold personal information about you. This information might include:
- personal information to identify and contact you, such as your name, address, contact details and date of birth
- information about your work or profession, your nationality and education
- results of psychometric and other assessment reports to support recruitment, onboarding and development
- details of when you contact us and when we contact you
- other information that you supply to us or that we obtain from our relationship with you.
We may also ask you to provide ‘special category’ information about yourself (e.g. information about your health or ethnicity). Further information about how we use special category information is available later in this notice.
Where does Nationwide collect information from?
Information may be provided by you directly, your nominated referees, or a third party acting on your behalf (e.g. recruitment agency), or our service providers.
If you are successful and offered a role with Nationwide, we’ll collect and share your information with our pre- employment screening providers and other suppliers (e.g. credit reference & fraud prevention agencies) as part of our onboarding checks. This is so we can check the information you’ve provided to us is accurate, assess your suitability for the role (e.g. whether you have had a CCJ) and prevent criminal activity and financial crime, including fraud and money laundering. This may involve profiling whereby potential candidates are categorised for review by a Nationwide employee to see whether they meet our employment criteria.
How does Nationwide use your information?
Recruiting and onboarding people:
We collect and use your personal information when you apply for a role with us, either as an external or internal candidate. We’ll collect and use personal details to:
- Register your interest in working for Nationwide, when you have requested us to do so
- Add you to our talent pool to identify and contact you about alternative suitable roles
- Process your application to determine whether you are suitable and eligible to apply for the role
- Administer any interviews and psychometric testing
- Offer roles to successful candidates and complete onboarding checks
- Manage any queries and provide feedback.
Information may be provided by you directly or a third party acting on your behalf (e.g. recruitment agency).
As part of our recruitment processes, we may use technology to assess your application and whether you are suitable for the role (e.g. psychometric or ability tests). More information on how Nationwide uses automated decision making is provided below.
Preventing and detecting fraud and financial crime
The personal data you have provided or we have received from third parties about you will be will be shared with Cifas, the UK’s largest cross-sector fraud sharing organisation. This will be used to confirm that you are who you say you are, and to help stop financial crime including fraud, money laundering, other unlawful or dishonest conduct, malpractice, and other seriously improper conduct. If any of these are detected you could be refused certain services or employment. For further details of how your information will be used by us and Cifas, visit the CIFAS website.
Meeting our legal and regulatory obligations
At Nationwide, we are required to collect and use your personal information in a number of circumstances to meet our legal and regulatory obligations.
These include using your personal information to carry out a range of activities to ensure we comply with the requirements set out by our regulators (e.g. Financial Conduct Authority (FCA) & Prudential Regulation Authority (PRA) and in relevant legislation (e.g. Data Protection Legislation & Anti-Money Laundering Regulations).
We will have further regulatory obligations to collect and use information about those applying for Senior Manager or Certification Roles e.g. Financial Planning Managers, or for certain roles within Treasury. Information will be provided as part of your contract and job description.
Enhancing your experience when we recruit and onboard employees
Understanding more about you helps us to enhance candidates’ experiences when we are recruiting and onboarding them.
We collect and use your information to help us make our recruitment and onboarding processes better and ensure we engage with you in the right way. This includes:
- providing access to services to support you through our onboarding process
- personalising how we communicate with you
- understanding the diverse backgrounds of our employees to help inform our strategy and cater for your needs
- gaining insight on our candidates and how you interact with us so that we can analyse and understand where improvements can be made (e.g. how you use our recruitment and onboarding websites).
- developing our business and understanding how we’re performing as an employer
We do this by looking at your data (e.g. the location of the role you apply for) and how you engage with us (e.g. information about whether you access our onboarding services). We also review feedback surveys, to understand your thoughts on our recruitment and onboarding processes.
Then, we profile your information by structuring and analysing this information. This allows us to offer a personalised service on our recruitment and onboarding websites, improve relations and make our benefits and services for candidates better in the future.
Collecting ‘special category’ and sensitive personal information
Sometimes we will collect, or you might want to give us, information that we call ‘special category data’. This could be information about your health so that we can make reasonable adjustments for you during your recruitment journey, or in the workplace if you are offered a role. It could also be information about your ethnicity, religion or sexual orientation as part of our equal opportunities monitoring.
Normally we will collect this information to ensure that we can comply with our obligations under employment laws. You will be asked whether you wish to provide this information and we will provide you with the option to ‘prefer not to say’.
Please note, for employees based in Northern Ireland, we collect information about your religion. We will ask for you to provide this information as part of our obligations to the Equality Commission of Northern Ireland. You will be provided with the option if you would prefer not to provide this information.
Why do we use your information in this way?
We’ll process your information in this way when it’s required as part of entering into an employment contract with Nationwide.
In certain circumstances, we have a legal obligation to collect and use information about you (e.g. information to support your eligibility and right to work in the UK).
We may use your information where it is in the legitimate interests of Nationwide – primarily so that we can act on your request if you show an interest to working for us and ensure we uphold our duties as a responsible employer by recruiting suitable candidates. It is also in our interests to follow the guidance and best practice of our regulators to protect Nationwide and its members by completing checks on our potential employees. We’ll always ensure the way we process your information is safe and not unfair to you.
Automated Decision Making
At Nationwide, we sometimes use technology to make automated decisions about candidates as part of our recruitment process.
We consider the information you provide as part of your application together with any responses to the psychometric tests we may ask you to complete. This allows us to assess your suitability for the role, based on our recruitment policy and the experience and attributes we require for the role.
An example of an ADM we may use in our recruitment process is psychometric testing, which is regularly validated to ensure the tests are fair and unbiased. ADM may also include other methods of ensuring you meet the requirements for the role you have applied for and as part of our checks to prevent financial crime such as fraud and money laundering.
You have certain rights over your personal information when it comes to automated decisions made in relation to you. If you want to know more about these rights, please see “What are your rights around your personal information?” below.
Who might we share information with?
We will share information within the Nationwide Group; with organisations working on our behalf (e.g. providers supplying psychometric and background checks or for workplace adjustments); and with people or organisations that you have asked to act on your behalf.
We may also share information with fraud prevention agencies along with HMRC and other government bodies when permitted or required to do so by law. A list of the types of third parties we share information with is available on request.
Sending your information outside the UK
We may transfer information outside the UK e.g. to a third party who supports us in providing our systems. We will always make sure that your information is protected.
How long do we keep your information?
Our aim is to keep your information for as long as we need to, in order to manage your relationship with us and comply with legal and regulatory requirements. If your job application is unsuccessful, we’ll keep the information we have collected for 12 months from the point at which your candidate profile is last updated. If you are successful in your application and become an employee of Nationwide, your information will form part of your employee record and will be retained in line with our data retention schedules.
What are your rights around your personal information?
You have certain rights when it comes to your personal information. This includes rights to access and correct your information, and to erase, transfer, object to, restrict or take away consent around how we use your information. You also have the right to have automated decisions made about you reviewed by a member of the Nationwide recruitment team.
However, these rights might not be available to you in all circumstances. We’ll always consider your request and get back to you as soon as we can within one month. To submit a request please email specialistHR.firstname.lastname@example.org or write to Specialist Handling Team, Nationwide House, Pipers Way, Swindon, SN38 1HR.
In the event that we do not meet your expectations regarding your individual rights, you also have the right to complain to the Information Commissioner’s Office, who oversees data protection regulation in the UK. Their details can be found online at www.ico.org.uk.
Contact details for Nationwide’s Data Protection Officer
Nationwide’s Data Protection Officer (DPO) is responsible for protecting personal data held by Nationwide Building Society and its subsidiaries. You can contact them at the following address:
The Data Protection Officer
Nationwide Building Society Group