Candidate Data Privacy Policy

We’re delighted you want to work with us here at ClearBank! As with all potential employers, there are a few things we would like you to know about how we respect and manage your data privacy as a candidate.

What we need to know about you … 

When you apply to ClearBank, as your data controller, we will collect, store and use all the usual information you would expect us to in order to assess your suitability for the role you have applied for. For example, we will collect the following information about you:

1. Information you include on your CV, or which you tell us by completing forms or by corresponding with us by mail, phone, email or otherwise, such as personal contact details (i.e. name, title, addresses, telephone numbers, work and personal email addresses), education and training details, employment history including job titles, professional memberships, compensation history, copies of right to work documentation, and other similar information as needed to consider your application.

2. Information we receive through references from your former employers or as part of your background check from our background check providers who will carry out the appropriate checks for your role, such as:

3. Information we create about you, such as feedback on you in interviews and your tests scores (if applicable).

  • adverse media search,
  • customer credit search,
  • information on LinkedIn, Facebook, Instagram or other social media sites,
  • criminal records (basic disclosure),
  • directorships,
  • education,
  • employment gaps & employment history,
  • employment references,
  • FCA register check,
  • global sanctions & watchlist search,
  • identity checks,
  • professional qualifications & memberships and
  • UK consumer credit search.

3. Information we create about you, such as feedback on you in interviews and your tests scores (if applicable).

Other personal data we may process:

(a)     In the event that you are asked to attend at ClearBank’s office for an interview, we may process data regarding any of your disabilities, if any,  in order to make reasonable adjustments. In addition, ClearBank conducts live streaming of the offices via video link (please be aware that such streaming is running all the time but is not recorded and will not be used for any other purpose). We also want you to be aware that the building in which we operate has CCTV at the entrance of the building, and swipe card access systems, both at the entrance to the building and at the entrance to ClearBank’s office. Both the live streaming and CCTV systems are operated only for the security of the building and all people within the building and ClearBank does not intend to access such data about you for any other reason. 

(b)     In order to protect the vital interests of our employees, individual suppliers and customers, we also may collect some very sensitive personal data, including information about Criminal convictions, County Court Judgments or adverse financial checks, through our background checking process. We will delete information collected during such background checks, apart from any information we are obliged to keep as part of your employment/engagement by us, as soon as possible after receiving it and will only ordinarily keep a record that the checks were carried out).

(c)     Further information on how we retain and manage personal and sensitive personal data for our employees, individual suppliers and Non-Executive Directors (NED)s is available within our Data Lifecycle Policy within our Employee Handbook.

Why do we need to know all this?

We will process personal data about you as we need to: (a) in order to carry out the recruitment process prior to entering into any employment/engagement contract with you; (b) in order to comply with our legal obligations (for example, to check your right to work in the UK, to comply with our regulatory obligations as a regulated entity, to prevent fraud, etc.); and (c) for our legitimate interests – we need to check that you are suitable and legally able to work for ClearBank.

Who else will we share your information with?

  • During the recruitment process, we may pass on your details to our background screening service providers, First Advantage Europe Limited, to undertake background screening checks on you. During this process, First Advantage Europe Limited and/or its affiliates may disclose your personal data to affiliates and/or sub-processors to the extent necessary to assist with the checks, and to law enforcement and governmental agencies to check for civil and criminal records, as permitted by law.  Sources of information used during the vetting process may include governmental authorities and third-parties, such as prior employers and educational institutions you attended. 
  • In addition, as part of the background check process your personal data may be transferred outside the European Union (EU), including to the United States, in order to be processed by First Advantage staff operating outside of the EEA, or by one of First Advantages’ suppliers who operate in a country where they have no physical presence, but need to perform services such as employment / education verifications, or the retrieval of records from courthouses, police stations, credit databases etc.  If this transfer is to the United States such onward transfers of personal data will be consistent with the EU-U.S. Privacy Shield principles and the Swiss-U.S. Privacy Shield principles.  Where a transfer is to a non-EU jurisdiction, First Advantage will ensure such onward transfer of personal data will be afforded at least the same level of protection as is required by the Privacy Shield Principles and the First Advantage Corporation Privacy Policy. To view First Advantage’s certification under both Privacy Shield programs visit https://www.privacyshield.gov/list To view First Advantage’s Corporation privacy policy visit https://fadv.com/privacy-policy.aspx
  • We may on occasion share personal data we hold with other companies within our group. We will also share your data with others if we are under a duty to disclose it in order to comply with any legal obligation, other agreements; or to protect our rights, property, or safety of our employees, individual suppliers, customers, or others.

How long will we keep your data?

If your application is unsuccessful, all personal data collected within our recruitment process will be deleted within 6 months of your interview process with ClearBank. If you are successful, ClearBank will keep and use your personal data as set out above whilst your employment/engagement continues and for up to 7 years after it ends (unless ClearBank informs you otherwise).

In order to protect the vital interests of our employees, individual suppliers and customers, we also collect some very sensitive personal data through our background checking process such as Criminal convictions, County Court Judgments or adverse financial checks to highlight a few within the above section, and on disabilities in order to make reasonable adjustments, criminal convictions, County Court Judgments or adverse financial checks to highlight a few within the above section. Background checks will only be done in the event that you are actively moving through our on-boarding process. In order to respect your data privacy, we will delete information about your criminal and background checks as soon as possible after receiving it and will only keep a record that the checks were carried out (apart from any information we need to keep as part of your employment/engagement by us).

Further information on how we retain and manage personal and sensitive personal data for our employees, individual suppliers and Non-Executive Directors (NED)s is available within our Data Lifecycle Policy within our Employee Handbook.

Your rights.

Under certain circumstances, you have the right to:

  • ask for us to correct inaccurate personal data, to have any incomplete personal data completed and for us to pass this on to any third parties holding your personal data;
  • request erasure of your personal data and for us to pass this request on to recipients from us of your personal data;
  • request the restriction of processing of your data and for us to pass this on to other recipients from us of your personal data;
  • obtain from us confirmation as to whether or not your personal data is being processed and where that is the case, access your personal data and information regarding the processing of that data;
  • not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. 
  • where the processing is based on your consent, object to processing, withdraw your consent without affecting the lawfulness of processing based on consent before its withdrawal; and
  • request us to transfer your information to another party.

More information on these rights and how to exercise them is available on the Information Commissioner’s Office (ICO) website and contact information for ClearBank is provided below.

If you believe that we have not complied with our personal data protection obligations, we hope that you will be able to resolve this issue with us directly so contact us at ClearBank on Careers@Clear.Bank. You can also contact our Data Protection Officer, Stephen Collins on Stephen.Collins@Clear.Bank. However, you also have the right to complain to the ICO.

ClearBank® can be contacted at ClearBank Limited, Floor 5, 9 Devonshire Square, London, United Kingdom. This notice may be updated as necessary from time to time and does not form part of any contract of employment or other contract to provide services.