As part of our candidate application and recruitment process the RBS Group Plc. (the “bank”) collects, processes and stores personal information about you. We process this information for a range of purposes relating to the recruitment process and this may include your application, assessment, pre-employment screening, and your worker permissions. This document sets out:
- Why we collect your personal information;
- What information is collected and;
- How it is processed within the recruitment process.
Throughout this Privacy Notice we use the term “processing” to cover all activities involving your personal information, including collecting, handling, storing, sharing, accessing, using, transferring and disposing of the information.
1) Why do we collect your personal information?
In order to manage your application, we need to process certain personal information about you. The purposes for this are set out below. We only process your information as necessary for the purposes of progressing your application or as required by law or regulatory requirements, so not all of the purposes set out below will apply to you all of the time.
- Application 1, a: CV, name, address, employment history, academic and professional qualifications, age, diversity (i.e. gender. ethnicity, disability, sexual orientation ), nationality, previous disciplinary matters, parents educational attainment and eligibility for free school meals;
- Assessment: CV, psychometric tests (such as a situational judgement test, ability or personality test), interview (face to face, telephone or video), behavioural assessments (such as a role play, group exercise or presentation), technical assessments;
- Pre-employment screening (PES) 2, b: county court judgements, credit history, penalties for tax evasion (see sections 6, 7, 8, 9 & 10 for more information on PES screening)
2) What personal information might we process?
Here are some examples of the type of information we may process. There’s a full list in the schedule at the end of this notice.
- Personal details such as name, address, date and place of birth;
- Work history/job data; previous employers, positions, dates, etc.
- 3 Compensation; basic salary, benefits, bonuses, etc.;
- Education and work history including professional qualifications and skills;
- Employer feedback / references to include regulated references where necessary;
- c Nationality / visa / right to work permit information; (e.g. passport, driving licence, National Insurance numbers)
- Photographs and images from recorded assessments or from on site CCTV;
- 4 Results of Pre employment screening checks (e.g. credit history, criminal records checks where permitted under local law)
- Assessment results e.g. Psychometric assessment results, results from gamification and video or telephone assessment
During the process we also capture some sensitive personal data about you (e.g. disability information). We do this in order to make reasonable adjustments to enable our candidates to apply for jobs with us, to be able to take online/telephone assessments, to attend interviews/assessment centres, to prepare for starting at the bank (if successful) and to ensure that we comply with regulatory obligations placed on us with regard to our hiring.
3) Who do we share your personal information with?
The bank will need to share your personal information internally (both in the country where you may work and in other countries in which we have central operations) and may require to share it with some external parties or associates of the bank. Some of these third parties and associates will be located outside the European Economic Area (“EEA”). Your information will only be shared if it is necessary or required (for example in order to carry out Pre-employment screening).
The recruitment process will involve:
- Assessing and progressing your application,
- Assessing your suitability (skills, strengths, behaviours for the role)
- Activities needed to complete the on-boarding and screening process should your application be successful.
To enable these processes your personal information may be shared internally, but the information shared is limited to what is required by each individual to perform their role in the recruitment process.
Your personal information may be shared internally with the following people:
- Those employees who would have managerial responsibility for you or are acting on their behalf;
- Employees in HR who have responsibility for certain HR processes (for example recruitment, assessment, pre-employment screening);
- Employees in Legal, Conduct, Risk, HR, Regulatory and Fraud with responsibility for investigating issues of non-compliance with laws and regulations, policies and contractual requirements;
- Employees in IT and system owners who manage user access;
- Audit and Investigations employees in relation to specific audits/investigations; and
- Security managers for facilities / premises.
The bank may also need to share your information with certain external third parties including:
- Companies who provide candidate interview and assessment services to the bank;
- Suppliers who undertake background screening on behalf of the bank (credit checking agencies, criminal checking bureaus, etc.)
- Academic institutions d (Universities, colleges, etc.) in validating information you’ve provided
- Other third-party suppliers (or potential suppliers), who provide services on our behalf.
4) How do we protect your information?
Our HR and Recruitment systems are protected to ensure that unauthorised or unlawful processing of personal information, accidental loss or destruction of, or damage to, personal information does not occur. This is done in accordance with the RBS Security Policy.
Where we share information with other parties located outside your country, as a minimum, the bank will require that such personal information is protected as required by the laws of the country where you work. The bank also requires its third party suppliers or recipients of personal information to guarantee the same level of protection as provided by the bank. Your personal information will be retained in accordance with the bank’s Managing Records Policy (which means that we may hold some information after your application to the bank is complete).
5) Your Rights
You are entitled to see the information the bank holds about you. You can also request changes to be made to incorrect information. You can ask for information to be deleted or blocked if you legitimately think that the bank shouldn’t be processing that information, is processing it incorrectly.
If you have any queries about this notice or your personal information generally, including questions about accessing your personal information or correcting it, you should contact HR People Services in the first instance. Alternatively, there is information available on our internet about accessing your personal information, please search for “subject access requests”.
It is your responsibility to keep your personal information up to date so that accurate application records can be maintained. You can manage all of your applicant data by accessing and updating your profile on the banks applicant tracking system.
As this document is updated, the current versions will be posted on this site.
6) Screening checks
As part of the Selection process, the RBS Group Plc performs a number of screening checks, where permitted by local law. These checks are only performed on candidates who have been selected for a role. Your consent will be requested before screening checks are performed.
7) Criminal records checks
Given the nature of our business, we have legal and regulatory obligations to ensure that the people we employ can be relied upon to handle client money and information responsibly. We therefore ask questions about any prior civil or criminal proceedings you may have been subject to and may also conduct criminal record checks.
8) Credit reference agencies
We will undertake searches about you at credit reference agencies who will supply us with information, including information from the electoral register, in support of our recruitment decision. The agencies will record details of the search but will not make them available for use by lenders to assess your ability to obtain credit. We may use scoring methods to assess this application and to verify your identity.
You have the right of access to your personal records held by credit reference agencies. We will supply their names and addresses upon request.
9) Fraud prevention agencies
To prevent or detect fraud, or assist in verifying your identity, we may now and periodically make searches of Group records and at fraud prevention agencies. Should our investigations identify fraud or the commission of any other criminal offence by you (on your part) when applying for, or during the course of your employment with us, we will record details on this on fraud prevention databases. This information may be accessed from the UK and other countries and used by law enforcement agencies and by us and other employers (and potential employers) to prevent fraud. Please contact us if you want to receive details of the relevant fraud prevention databases through which we share information.
10) Regulatory screening
In order to comply with our legal and regulatory obligations in relation to anti-money laundering and sanctions restrictions, we will screen your name against global sanctions lists. The screening will simply involve searching our internal and third party databases to ensure you are not on a sanctioned list. We are not able to employ anyone on a sanctions list. In addition, in order to comply with our legal obligations relating to anti-bribery and corruption, we will also perform searches and ask questions to assess whether there is a potential bribery or corruption risk to the role based on your personal and political associations. If there is a risk we will look to assess what additional internal controls we need to put in place to reduce that risk.
11) Processing Conditions
The bank’s entitlement to process your personal information is governed by a number of processing conditions. This means that we may rely on more than one of these conditions in order to process elements of your personal information throughout the recruitment process.
- The bank will process your personal information in the administration of your application.
- The bank will also process your personal information where it is required by law or regulation or it is in the legitimate interests of the applicant or the bank. This processing will always be fair and lawful and will at all times comply with the principles of applicable privacy laws in the country where you have applied to be employed.
- During the course of your application it may also be necessary for the bank or its suppliers to process your sensitive personal information as per the detail in section 2 and Schedule 1 of this notice. This processing will be carried out on the basis of 6(a) and 6(b) above, as well as your express consent which is captured as part of the recruitment process.
Poland: The following specifically relate to Poland:
- 1 diversity (i.e. gender. ethnicity, disability, sexual orientation), previous disciplinary matters, parents educational attainment and eligibility for free school meals are not collected in Poland
- 2 county court judgements, credit history, penalties for tax evasion are not collected in Poland
- 3, 4 are only collected and processed for employees
- 5, 6, 7, 8 the labelled items listed in this privacy notice are not collected in Poland
India: The following specifically relate to India:
- a parents educational attainment and eligibility for free school meals – details are not collected in India
- b county court judgements, credit history, penalties for tax evasion are not collected in India, but court room checks for last 2 years at the residential address are conducted.
- c in addition Permanent Account Number (PAN), Aadhar Card, Universal account number (UAN), National Insurance numbers are recorded
- d and also the previous organisation where you may have worked in past
- e In India our third party vendor will checks details against the ‘Credit and Reputational risk’ database for India and ‘Serious and Organised crime’ global database, ‘Regulatory authorities database’ global database, ‘Compliance authorities database’ global check
- f Military service is not checked or processed in India
- g References may be obtained as part of recruitment process in India
Schedule 1: Full list of information we may process g
- Name, work and home contact details
- Date and place of birth
- Education and work history
- * Individual demographic information in compliance with legal requirements (such as marital status, national identifier, passport/visa information, nationality, citizenship, military service, disability, work permit, date and place of birth or gender)
- * Health issues requiring adaptations to working environment
- Job title, grade and job history
- 5 Employment contract related information (including compensation, location, hours of work and so on)
- Reporting and managerial relationships
- * Leaves of absence (such as maternity leave, sickness absence)
- 6 Disciplinary / grievance records
- Time and attendance details
- * Bank account details for salary payment purposes
- 7 Expenses such as travel and expenses claimed from the bank
- Skills and qualifications
- Training history and plans
- Results of original and ongoing employee screening, where relevant (see section 6)
- Details provided in relation to Conduct policies (such as conflicts of interest, personal account dealing, trade body membership and so on)
- 8 * Health & safety incidents, accidents at work and associated records
- Building CCTV images
- Audio recordings of telephone interviews
- Video recordings of interviews
- Notes from face to face interviews
- Psychometric test results and associated reports
- Results from behavioural assessments (e.g. Assessment Centre exercises)
- Results from technical assessments
* These categories of information might potentially include some sensitive personal information. Sensitive personal information is not routinely collected about all applicants, it may be collected where the bank has a legal obligation to do so, or if you choose to disclose it to us during the course of your relationship with the bank.