Applicant and Colleague Privacy Notice

Introduction

Monument Bank Limited ("Monument") (company number 10921940) whose registered office is at 33 Cavendish Square, London, W1G 0PW 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 working relationship with us, in accordance with the Data Protection Act 2018 and related legislation.

It applies to all employees, workers, contractors and job applicants.

Monument is a "data controller". This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

This notice applies to current and former employees, workers, contractors and job applicants. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time but if we do so, we will provide you with an updated copy of this notice as soon as reasonably practical.

It is important that you read and retain this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.

The kind of information we hold about you

We will collect, store, and use the following categories of personal information about you:

Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
Date of birth.
Gender.
Marital status and dependents.
Next of kin and emergency contact information.
National Insurance Number.
Bank account details, payroll records and tax status information.
Salary, annual leave, pension and benefits information.
Start date and, if different, the date of your continuous employment.
Leaving date and your reason forleaving.
Location of employment or workplace.
Copy of driving licence, Passport, or other Identification document as agreed byus.
Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process).
Employment records (including job titles, work history, working hours, holidays, training records and professional memberships).
Compensation history.
Performance information.
Disciplinary and grievance information.
CCTV footage and other information obtained through electronic means such as swipe cardrecords.
Information about your use of our information and communications systems.
Photographs.
Results of HMRC employment status check, details of your interest in and connection with the intermediary through which your services are supplied (as relevant).

Special category data

SITUATIONS IN WHICH WE WILL USE YOUR SPECIAL CATEGORY DATA

In general, we will not process special category data about you unless it is necessary for performing or exercising obligations or rights in connection with employment. On rare occasions, there may be other reasons for processing, such as it is in the public interest to do so. The situations in which we will process special category data are listed below. We have indicated the purpose or purposes for which we are processing or will process special category data.

We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits including statutory maternity pay, statutory sick pay, pensions and permanent health insurance. We need to process this information to exercise rights and perform obligations in connection with your employment.
If you leave employment and under any equity plan operated by us or a group company the reason for leaving is determined to be ill-health, injury or disability, we will use information about your physical or mental health, or disability status in reaching a decision about your entitlements under the equityplan.
Going forward, we will seek to use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
Where relevant, we will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations.

DO WE NEED YOUR CONSENT?

We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.

Information about criminal convictions

We may only use information relating to criminal convictions where the law allows us to do so. This will usually be where such processing is necessary to carry out our obligations and provided we do so in line with our Data Protection Policy.

We envisage that we will hold information about criminal convictions.

We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences in the following ways:

To understand and assess whether the criminal conviction has any impact on the appropriateness of you continuing to perform your role within the Bank.
Making decisions about your continued employment or engagement.
Making arrangements for the termination of our working relationship.

We are allowed to use your personal information in this way to carry out our obligations in respect of managing our risk exposure effectively. This includes being able to identify and address any issues relating to criminal conduct which may affect your suitability for employment with us. We have in place an appropriate policy and safeguards which we are required by law to maintain when processing such data.

The personal information we collect from you will be shared with the fraud prevention agency, Cifas who will use it to prevent fraud, other unlawful or dishonest conduct, malpractice, and other seriously improper conduct. If any of these are detected certain services or employment could be refused. Your personal information will also be used to verify your identity. Further details of how your information will be used by us and Cifas, and your data protection rights, can be found at Fair Processing Notices for Cifas' Databases | Cifas

How is your personal information collected?

We collect personal information about employees, workers, contractors and job applicants through the application and recruitment process, either directly from job applicants or sometimes from an employment agency or background check provider. We will collect additional information from third parties including former employers, credit reference agencies or other background check agencies.

We may also collect personal information from the trustees or managers of pension arrangements operated by a group company.

We will collect additional personal information in the course of job-related activities throughout the period of you working for us.

How we will use information about you

We need all the categories of information in the list above, and in the table set out below, primarily to allow us to perform our contract with you and to enable us to comply with legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed in the table at the end of this document. Some of the grounds for processing will overlap and there may be several grounds which justify our use of your personal information. Alternatively, we will obtain your consent where we require it to process your personal data, and none of the other legal grounds described above or in the table below, is more appropriate. We may also use your personal information in the rare situations where:

we need to protect your vital interests (or someone else's interest). (Protecting vital interests means when we may need to provide information to save your or someone else's life); or
where it is necessary to do so in public interest or for official purposes. (An example of this is when we are asked to process colleague salary information for the purposes of benefits investigations).

We will, however, only use your personal information for the purposes which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. We may process your personal information without your knowledge or consent, where this is required or permitted by law.

Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

Where we have notified you of the decision and given you 21 days to request areconsideration.
Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard yourrights.
In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

If we make an automated decision on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

Data sharing

WHY MIGHT YOU SHARE MY PERSONAL INFORMATION WITH THIRD PARTIES?

We will share your personal information with third parties in the following situations:

where required by law or by UK banking regulation
where it is necessary to administer the working relationship with you;or
where we have another legitimate interest in doing so to enable our business to function appropriately.

WHICH THIRD-PARTY SERVICE PROVIDERS PROCESS MY PERSONAL INFORMATION?

"Third parties" includes third-party service providers (including contractors and designated agents) and other entities within our group.

We engage with a number of third-party service providers that carry out activities on our behalf. These include: providing office premises, recruitment and onboarding checks, payroll, pension administration, provision of employee benefits and their administration and IT and communication services.

Further details in respect of who we may provide your personal information to can be obtained from Head of People upon request.

HOW SECURE IS MY INFORMATION WITH THIRD-PARTY SERVICE PROVIDERS?

All our third-party service providers 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.

WHAT ABOUT OTHER THIRD PARTIES?

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. In this situation we will, so far as possible, share anonymised data with the other parties before the transaction completes. Once the transaction is completed, we will share your personal data with the other parties if and to the extent required under the terms of the transaction.

We may also need to share your personal information with a regulator or to otherwise comply with the law. This may include making regulatory applications or notifications, completing returns to HMRC, disclosures to stock exchange regulators (including a Regulatory News Service) and disclosures to shareholders such as directors' remuneration reporting requirements.

Transferring information outside the EEA

Our aim is not to transfer your personal information outside the EEA, unless it is unavoidable to deliver our services. As part of our recruitment and onboarding processes, we may transfer it outside the EEA as follows:

To third parties from which personal information must be collected or verified to fulfil our screening and onboarding checks.
To contractors that provide specific services to verify information we have received. For example, it may be necessary to transfer personal information to a company in Russia in order to verify educationhistory.
To you if you are based outside the EEA.

As part of the onboarding process, we will seek your consent to the transfer to allow us to carry out the checks.

If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the Data Protection Legislation. Such steps may include, but not be limited to, the use of legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved model clauses agreements.

Data Security

We have put in place measures to protect the security of your information. Details of these measures are available upon request.

Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.

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. Details of these measures may be obtained from the Head of People.

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?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Details of retention periods for different aspects of your personal information are available in our Data Retention Policy which is available from Colleague Information folder, or on request from the Data Protection Lead. 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 and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

Rights of access, correction, erasure, and restriction

YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.

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 the Head of People in writing.

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.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Head of People. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Data protection lead

We have appointed the Chief Compliance Officer as the Data Protection Lead, to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please email dataprotection@monument.co. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

Changes to this privacy notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

If you have any questions about this privacy notice, please email dataprotection@monument.co.

Situations in which we will use your Personal Data

Situation	Data category	Processing purpose
Making a decision about your recruitment or appointment (to include assessing your skills, qualifications and suitability and communicating with you accordingly)	Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses Immigration Status Photograph Place of Birth Gender Address History Nationality Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process such as at interview) Employment records (including job titles, work history, working hours) Disclosure Barring Service check and other relevant criminal record checks Outside business interests Compensation history Performance information Disciplinary and grievance information Financial History, including credit reports Bankruptcy Tax Information Real Estate Ownership Credit Checks Cifas fraud database checks	To pursue our legitimate interest in selecting suitable personnel
Determining the terms on which you work for us	Salary, annual leave, pension, equity plans, incentive plans and benefits information Start date Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process such as at interview) Employment records (including job titles, work history, working hours) Compensation history Performance information Disciplinary and grievance information Credit checks Disclosure Barring Service check Cifas fraud database checks	To pursue our legitimate interest in administering a working relationship with you
Checking you are legally entitled to work in the UK	Copies of identification documents such as passport and driving licence Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process such as at interview)	To enable us to comply with legal obligations
Security of employees and Monument premises	CCTV images, photographs (security passes)	Legitimate interest in ensuring the premises at which employees work is safe and employees are easily identifiable
Paying you and, if you are an employee, deducting tax and National Insurance contributions	Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses Date of birth Marital status and dependents National Insurance number Bank account details, payroll records and tax status information Salary, annual leave, pension and benefits information Start date Leaving date	To allow us to perform our contract with you and to enable us to comply with legal obligations
Providing benefits to you	Date of birth Gender Marital status and dependents National Insurance number Bank account details, payroll records and tax status informationSalary, annual leave, pension and benefits information Start date Location of employment or workplace Information about your health, including any medical condition, health and sickness records	To allow us to perform our contract with you. To enable us to comply with legal obligations and exercise specific rights
Liaising with your pension provider	Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses Date of birth Gender Marital status and dependants National Insurance number Bank account details, payroll records and tax status information Salary, annual leave, pension and benefits information Start date Leaving date	To allow us to perform our contract with you
Administering a contract we have entered into with you	Bank account details, payroll records and tax status information Salary, annual leave, pension and benefits information Start date Location of employment or workplace Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process such as at interview) Employment records (including job titles, work history, working hours)	To allow us to perform our contract with you
Business management and planning, including accounting, auditing and insurance	Next of kin and emergency contact information Salary, annual leave, pension and benefits information Location of employment or workplace Security photographs and CCTV footage Employment records (including job titles, work history, working hours) Electronic entry card/key fob data	To pursue our legitimate interest in operating our business effectively
Conducting performance reviews, managing performance and determining performance requirements	Salary, annual leave, pension, equity plans, incentive plans and benefits information Start date Location of employment or workplace Employment records (including job titles, work history, working hours) Compensation history Performance information Disciplinary and grievance information Disclosure Barring Service check and other relevant criminal record checks Credit checks	To enable us to comply with legal obligations. To pursue our legitimate interest in ensuring our business continues to employ those identified as fit and proper to work within a regulated financial institution
Making decisions about salary reviews and compensation	Salary, annual leave, pension, equity plans, incentive plans and benefits information Start date Employment records (including job titles, work history, working hours Compensation history Performance information Disciplinary and grievance information	To allow us to perform our contract with you, to enable us to comply with legal obligations and to pursue our legitimate interest in growing and managing our business
Assessing qualifications for a particular job or task, including decisions about promotions	Start date Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process such as at interview) Employment records (including job titles, work history, working hours) Compensation history Performance information Disciplinary and grievance information	To allow us to perform our contract with you and to pursue our legitimate interest in growing and managing our business
Gathering evidence for possible grievance or disciplinary hearings	Location of employment or workplace Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process such as at interview) Employment records (including job titles, work history, working hours) Compensation history Performance information Disciplinary and grievance information	To allow us to perform our contract with you, to enable us to comply with legal obligations and to pursue our legitimate interest in managing our business
Making decisions about your continued employment or engagement	Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process such as at interview) Employment records (including job titles, work history, working hours) Disclosure Barring Service check and other relevant criminal record checks Credit checks Compensation history Performance information Disciplinary and grievance information Information about your use of our information and communications systems Cifas fraud database checks	To allow us to perform our contract with you and to pursue our legitimateinterest in managing ourbusiness
Making arrangements for the termination of our working relationship	Bank account details, payroll records and tax status information Location of employment or workplace Employment records (including job titles, work history, working hours) Leaving date	To allow us to perform our contract with you and to pursue our legitimateinterest in managing ourbusiness
Education, training and development requirements	Employment records (including job titles, work history, working hours) Performance information	To allow us to perform our contract with you and to enable us to comply with legal obligations
Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work	Employment records (including job titles, work history, working hours) Disciplinary and grievance information Information about your use of our information and communications systems	To allow us to perform our contract with you and to enable us to comply with legal obligations
Ascertaining your fitness to work	Information about your health, including any medical condition, health and sickness records	To allow us to perform our contract with you and to enable us to comply with legal obligations
Managing sickness absence	Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses Employment records (including job titles, work history, working hours)	To allow us to perform our contract with you and to enable us to comply with legal obligations
	Information about your health, including any medical condition, health and sickness records	To enable us to comply with legal obligations and exercise specific rights
Complying with health and safety obligations (including assessing any need for appropriate adjustments)	Next of kin and emergency contact information Location of employment or workplace	To allow us to perform our contract with you and to enable us to comply with legal obligations
	Information about your health, including any medical condition, health and sickness records	To enable us to comply with legal obligations and exercise specific rights
To prevent fraud	Copies of identification documents such as passport and driving licence Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process such as at interview) Employment records (including job titles, work history, working hours) Disciplinary and grievance information Credit checks Cifas fraud database checks	To enable us to comply with legal obligations and to pursue our legitimate interest in preventing criminal activity Share with the fraud prevention agency, Cifas who will use information provided to prevent fraud, other unlawful or dishonest conduct, malpractice, and other seriously improper conduct.
To monitor your use of our information and communication systems (to include reading your emails and calendar and checking computer log-in details) to ensure compliance with our IT policies and legal and regulatory obligations	Information about your use of our information and communications systems	To enable us to comply with legal obligations and to pursue our legitimate interest in managing our business
To enable you to register with external services utilised by us	Personal contact details such as name, title, telephone number.	To enable us to perform our contract with you and to pursue our legitimate interest in ensuring our business is run compliantly.
To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution	Information about your use of our information and communications systems	To enable us to comply with legal obligations and to pursue our legitimate interest in protecting systems and data
To conduct data analytics studies to review and better understand employee retention and attrition rates	Date of birth Gender Marital status and dependents Salary, annual leave, pension and benefits information Start date Location of employment or workplace Recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process such as at interview) Employment records (including job titles, work history, working hours) Compensation history Performance information Disciplinary and grievance information Leave date	To pursue our legitimate interest in growing and managing our business
Equal opportunities monitoring	Date of birth Gender Marital status and dependants Educational and personal circumstances	To enable us to comply with legal obligations
	Information about your race or ethnicity, religious beliefs, sexual orientation and political opinions	To enable us to comply with legal obligations and exercise specific rights
	Trade union membership	To enable us to comply with legal obligations and exercise specific rights
	Information about your health, including any medical condition, health and sickness records	To enable us to comply with legal obligations and exercise specific rights
To ensure suitability for employment	Disclosure Barring Service check and other relevant criminal record checks Cifas fraud database checks	To check suitability for the role Prevention of fraud and protecting the public against dishonesty. Regulatory requirementsLegitimate interest - managing Monument's risk profile as a regulated entity Compliance with legal obligations.

*Items marked with an asterisk may be considered sensitive or may be subject to special protections in some places. We will not collect them in every case. We will not collect them if it is illegal. Where permitted, we will only collect and use them in line with the law.

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