Ikano Bank (AB) publ Candidate Privacy Notice

What is the purpose of this document?

Ikano Bank AB (publ) (“We”, “Ikano Bank” or “the Bank”) is committed to protecting the privacy and security of your personal information.

This privacy notice describes how we collect and use personal information about you during and after your application for a role as an employee or for other work at Ikano in accordance with the UK General Data Protection Regulation (UK GDPR).

Where this privacy notice refers to “work” this includes work as a contractor, consultant, or for work experience. If a section of the privacy notice does not apply to certain types of work, we have explained this in the relevant section of the privacy notice. If you are successful in your application, we will provide you with our Co-worker Privacy Notice which explains how we use your personal data when you work at Ikano. Ikano is a "controller" in relation to personal data. This means that we are responsible for deciding how we hold and use personal information about you. This privacy notice makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the UK General Data Protection Regulation (UK GDPR).

Data protection principles

1. We will comply with data protection law and principles, which means that your data will be:
2. Used lawfully, fairly and in a transparent way.
3. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
4. Relevant to the purposes we have told you about and limited only to those purposes.
5. Accurate and kept up to date.
6. Kept only as long as necessary for the purposes we have told you about.
7. Kept securely.

The kind of information we hold about you

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

There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person's health or sexual orientation. Information about criminal convictions also warrants this higher level of protection.

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

• The information you have provided to us in your curriculum vitae and covering letter, such as employment history and qualifications.
• The information you have provided on our application form, including name, address, telephone number, personal email address, date of birth, employment history, qualifications.
• If you apply via LinkedIn, the information in your LinkedIn profile.(We will have access to this information but we will not store it on our systems).
• Any information you provide to us during an interview.
• Proof of your eligibility to work in the UK. *
• Identity documents such as your passport or driving licence*
• Proof of your postal address.*
• Proof of change of name, such as marriage certificate or deed poll if your proof of address is in a different name to your Identity documents.*
• We may also collect, store and use the following types of more sensitive personal information:
• Limited information about your health, or disabilities to enable us to make any reasonable adjustments you require as part of the interview process.
• Information about criminal convictions and offences.*

* we do not collect the personal data marked * when you apply for work experience.

How is your personal information collected?

We collect personal information about candidates from the following sources:

• You, the candidate.
• A recruitment agency, if is there is one involved in your application.
• HireRight Limited our background check provider, from which we collect the following categories of data: Results of full financial credit checks, identification checks and anti-money laundering checks, Bank of England Terrorist checks, staff fraud database checks, verification of your highest academic qualifications, verification of your professional qualifications, information from fraud prevention agencies, confirmation of the last 6 years of previous employment history from your named referees, information provide in your fitness and propriety statement, information from publicly available sources such as the FCA Register, and the media. If you are a contractor who works through a limited company we will also collect information about your limited company.*
• Disclosure and Barring Service in respect of criminal convictions.*
• LinkedIn, if you share your profile with us during the recruitment process.

* We do not collect information from the sources marked * when you apply for work experience.

How we will use information about you

We will use the personal information we collect about you to:

• Assess your skills, qualifications, and suitability for the role.
• Carry out background, credit and reference checks.*
• Check your details against fraud prevention databases.*
• If you are a contractor who works through a limited company, to carry out anti-money laundering checks on your limited company.
• Communicate with you about the recruitment process.
• Keep records related to our hiring processes.
• Comply with legal or regulatory requirements.

We do not use information in the ways marked * when you apply for work experience.

It is in our legitimate interests to carry out a fair recruitment process, arrange interviews, assess your suitability and decide whether to appoint you to the role or work and to communicate with you throughout the process, since it would be beneficial to our business to appoint someone to that role.

We also need to process your personal information to take steps at your request to prior to enter into a contract of employment or other contract with you.

In some cases we need to process data to comply with a legal or regulatory obligation which we are subject to for example to check your eligibility to work in the UK.

Having received your applications), we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role or work. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role or work. If we decide to offer you the role or work, we will send you a conditional offer of employment then take up references AND carry out a criminal record AND carry out background checks before confirming your appointment.

If you fail to provide personal information

If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a credit check or references for this role or work and you fail to provide us with relevant details, we will not be able to take your application further.

How we use particularly sensitive personal information

We will use your particularly sensitive personal information in the following ways:

• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during an interview.
• Information about criminal convictions

We envisage that we will process information about criminal convictions.

We are required to carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. For roles that are part of the Financial Conduct Authority’s Senior Management and Certification Regime we carry out a Standard DBS check and for all other roles we carry out a basic DBS check. In particular:

• We are legally required by the Financial Conduct Authority to carry out criminal record checks for those working at Ikano.
• For roles or work requiring a high degree of trust and integrity also seek a basic disclosure of your criminal records history.

We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.

Automated decision-making

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Data sharing

We may have to share your data with third parties, including third-party service providers. Many of our operations are undertaken on a group wide basis, and therefore we may have to share your information with other members of the Ikano Group.

We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your personal information outside the UK.

If we do, you can expect a similar degree of protection in respect of your personal information.

Why might you share my personal information with third parties?

We will share your personal information with the following third parties for the purposes of processing your application: HireRight Limited, the Disclosure and Barring Service, CIFAS (fraud prevention database). 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.

If as part of our pre-employment checks we identify fraud or the commission of any other criminal offence by you we will record the details of this on the relevant 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 organisations to prevent fraud.

Transferring information outside the UK and EU/EEA

Sometimes the personal information we collect about you will be transferred out of the UK or the EU/EEA. We also use third party suppliers to process limited personal data about you. Some of these suppliers may be located in countries outside of the UK and EU/EEA which may not have equivalent laws in place to protect your personal data.

We will in these cases ensure that your personal data is kept securely and only used for the purposes set out in this Privacy Notice. We do this through various mechanisms, for example ensuring that we are transferring to countries where the third country in question ensures an adequate level of protection or where appropriate safeguards are in place in accordance with the requirements in the EU and UK GDPR as well as ensuring that there are contractual obligations in place, such as standard contractual clauses.

A copy of the European standard contractual clauses is available here.

A copy of the UK International Data Transfer Agreement and International Data Transfer Addendum is available here.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

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

Data retention

How long will you use my information for?

If your application is not successful we will retain your personal information for a period of 6 months from the date of your application. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with our data retention policy.

If your application is successful your personal data will be retained in line with our Co-worker privacy policy which will be provided to you before you sign your contract of employment.

Rights of access, correction, erasure, and restriction

Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact HRUK@ikano.net.

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice and data protection legislation. If you have any questions about this privacy notice or how we handle your personal information, please contact the DPO at DPO@ikano.se. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) who is responsible for data protection issues in the UK.