European Regulatory Disclosures

The amended and recast Markets in Financial Instruments Directive and Regulation (MiFID II) and other important information

Background

NAB London is currently subject to the Markets in Financial Instruments Directive (MiFID I), as implemented in the United Kingdom. From 3 January 2018, NAB London will become subject to MiFID II.

MiFID II will impact the majority of European Economic Area (EEA) financial services providers (including NAB London) and the way in which they provide investment services to both EEA and non-EEA clients.

This site contains information regarding NAB’s MiFID II response and will be updated with further information closer to the compliance date, and in the case of the items listed below by the dates set out.

What will MiFID II mean for your dealings with NAB?

Where required, NAB will contact you directly to provide you with updated documentation to ensure we can continue to provide you with financial services and maintain our compliance with relevant regulations.

More Information about NAB’s MiFID II Response

If you have any queries in respect of NAB’s response to MiFID II, please contact MiFID.II.Regulatory.Queries@nab.com.au

Important disclosures

NAB London Data Protection Notice

Respecting your Privacy

National Australia Bank Limited which has its UK branch (number BR001924) at 88 Wood Street, London EC2V 7QQ (‘NAB’, ‘we’ or ‘us’) provides banking services to businesses. This Data Protection Notice tells you how we collect, use, store and share personal information when we provide these services.

This Data Protection Notice is aimed at individuals who interact with us on behalf of our business clients (‘you’ or ‘your’). We respect your personal information, and take appropriate measures to ensure NAB can engage securely with and for our clients and you.

NAB also has a Privacy Policy and, to the extent of any inconsistency, this Data Protection Notice will prevail in relation to your dealings with NAB’s London Branch.

What personal information do we collect and hold?

General Information

The types of information that we collect and hold about you could include:

  • ID information such as your name, postal or email address, telephone numbers, and date of birth;
  • professional information such as your job title and work experience;
  • information which we might need to conduct ‘know your client’ checks such as details relating to your passport and credit history;
  • information which arises or is required in connection with the transactions you do with us or through us; and
  • other information you may provide to us in the course of your dealings with us.

What sensitive information do we collect?

In limited circumstances, we need to collect special category information about you. Our money laundering, sanctions, financial crime and fraud prevention checks may result in us obtaining information about actual or alleged criminal convictions and offences.

How do we collect your personal information?

How we collect and hold your information

There are many ways we seek information from you. We might collect your information when you contact us by email, telephone or letter. Sometimes we collect information about you from other sources, including where information about you is publicly available (for example from public registers) or made available by third parties. For instance, we do this where:

  • your employer and its employees have given us your contact details;
  • we need to verify your details;
  • we need information for fraud or crime prevention purposes;
  • you have explicitly consented to third parties sharing it with us; or
  • we exchange information with your legal advisers or other representatives.

Under Money Laundering Regulations, NAB is required to ‘know its clients’. This requires us to ensure that the personal information for all of our clients is correct. We may do this by combining the information that we hold with information collected from or held by external sources.

In addition, we may monitor, measure, analyse and record all telephone and electronic communications with you.

What if you don’t want to provide us with your personal information?

If you don’t provide your personal information to us, we may not be able to:

  • communicate with you;
  • provide you or your business with our full services; or
  • verify your identity or protect against fraud.

How do we take care of your personal information?

We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure. Some of the ways we do this are:

  • confidentiality requirements and privacy training of our employees;
  • document storage security policies;
  • security measures to control access to our systems and premises;
  • only giving access to personal information to a person who is verified to be able to receive that information;
  • ensuring third parties meet our privacy obligations; and
  • electronic security systems, such as firewalls and data encryption on our websites.

We can store personal information physically or electronically with third party data storage providers. Where we do this, we use contractual arrangements to ensure those providers take appropriate measures to protect that information and restrict the uses to which they can put that information.

What happens when we no longer need your information?

We’ll only keep your information for as long as we require it for our purposes. We’re also required to keep some of your information for certain periods of time under law. When we no longer require your information, we’ll ensure that your information is destroyed or de-identified.

How we use your personal information

What are the main reasons we collect, hold and use your information?

We may process information about you for the purposes of the following legitimate interests:

  • providing products and services requested by you;
  • performing administrative and operational tasks within our business;
  • identifying you or verifying your authority to act on behalf of a client;
  • performing credit reference checks;
  • preventing or investigating any fraud or crime, or any suspected fraud or crime;
  • marketing financial products provided by us;
  • to establish, exercise or defend our legal rights,

or for compliance with a legal obligation or the request of a regulatory body.

We may process sensitive information about you to comply with law or for the prevention, investigation and detection of criminal acts, terrorist financing, fraud and money laundering (or for the purposes of any related prosecution).

Can we use your information for marketing our products and services?

We may use or disclose your personal information to let you know about products and services that we believe may be of interest to your business, including products and services from our related companies or from those we distribute products on their behalf. We will not do this if you tell us not to.

Such marketing activities may be via email, telephone, mail, or any other electronic means. You can let us know at any time if you wish to be removed from our marketing mailing lists or change your marketing preferences (see ‘Contact Us’). We will process your request as soon as practicable.

Who do we share your personal information with?

For the purposes described in ‘How we use your personal information’, we sometimes need to share your personal information with others. We may share your information with other organisations for any purposes for which we use your information.

Sharing with the NAB Group

We may share your personal information with other offices within NAB and related companies, including subsidiaries (‘NAB Group’). This could depend on the transaction your business does with us and the NAB Group member you are dealing with but will not differ from those purposes outlined above. Where appropriate we integrate the information we hold across the NAB Group to provide us with a complete understanding of the transaction and the needs of your business.

Sharing with third parties

We may disclose your personal information to third parties outside of the Group, including:

  • those involved in providing, managing or administering the service;
  • credit reporting bodies or other approved third parties who are authorised to assess the validity of identification information;
  • fraud reporting agencies (including organisations that assist with fraud investigations and organisations established to identify, investigate and/or prevent any fraud, suspected fraud, crime, suspected crime, or misconduct of a serious nature);
  • service providers that maintain, review and develop our business systems, procedures and technology infrastructure, including testing or upgrading our computer systems;
  • our joint venture partners that conduct business with us;
  • organisations involved in a corporate re-organisation or transfer of NAB Group assets or business;
  • organisations that assist with our product planning, analytics, research and development;
  • other organisations involved in our normal business practices, including our agents and contractors, as well as our accountants, auditors or lawyers and other external advisers;
  • government or regulatory bodies as required or authorised by law (in some instances these bodies may share it with relevant foreign authorities); and
  • where you’ve given your consent or at your request, including to your representatives, or advisors.

Sharing outside of the EEA

We are part of the NAB Group, which means that we deal with many international organisations and use global information systems, including in Australia where NAB is headquartered. As a result, we may need to share some of your information with organisations outside of the European Economic Area, which have lower standards of data protection than in your home jurisdiction. Where we do so, we will take steps to ensure that the transfer is subject to appropriate safeguards in accordance with data protection laws. Often, these safeguards include contractual safeguards. You can view a list of the countries in which those overseas organisations are located (in addition to Australia) at www.nab.com.au/privacy/overseas-countries-list/.

We may store your information in cloud or other types of networked or electronic systems. As electronic or networked systems can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed.

What rights do you have under data protection laws?

Data protection laws provide you with various rights. In particular, in the UK you have a right to:

  • request a copy of the information we hold about you;
  • ask that we update the information we hold for you, or correct information you think is incorrect of incomplete;
  • ask that we restrict processing your information;
  • ask that we delete the information we hold about you;
  • object to use of the information we hold about you, including being removed from marketing mailing lists; and
  • withdraw consent to our processing of your information (to the extent such processing is based on consent) or otherwise object to our processing of your information.

If you wish to exercise any of the rights listed above, you can tell us. See ‘Contact Us’.

These rights are not absolute: they don’t always apply. If we don’t comply with your request, we will explain why.

How do you access your personal information?

You can ask us to access your personal information that we hold by sending us a request. In some cases we may be able to deal with your request over the phone.

If we can’t give you access, we will tell you why in writing. If you have concerns, you can complain. See ‘Contact Us’.

Changes to this Data Protection Notice

This Data Protection Notice may change from time to time. Please visit our website regularly as we will let you know of any changes to this Data Protection Notice by posting a notification on our website. In addition, over the course of our relationship with you, we may tell you more about how we handle your information. This could be when you complete an application or form, or receive important disclosure documents from us, such as terms and conditions or a product disclosure statement. We recommend that you review these statements too as they may have more specific detail for your particular product holdings.

How do you make a complaint?

If you have a complaint about how we handle your personal information, we want to hear from you. You are always welcome to contact us (see ‘Contact Us’). We are committed to resolving your complaint and doing the right thing.

If you still feel your issue hasn't been resolved to your satisfaction, then you can escalate your privacy concern to the Information Commissioner. Her website is available at http://ico.org.uk.

Contact us

We care about what you think. Please contact us if you have any questions or comments about our privacy policies and procedures. We welcome your feedback.

You can contact us by getting in touch with your usual NAB contact or at nab.london.data.protection@eu.nabgroup.com

NAB London Complaints Procedure

Complaints procedure

NAB places great importance on providing the highest standards of service to our customers.

If you feel that on this occasion we have not met the high standards we strive to achieve then we encourage you to let us know. Your feedback is important as it allows us to improve our services and the products that we offer.

We aim to get your complaint resolved as quickly as possible by the appropriate staff with the experience, knowledge and authority to handle your complaint efficiently and effectively.


We therefore aim to:

  • make it easy for you to raise your complaint;
  • listen to your complaint;
  • consider your suggestions in putting matters right;
  • ensure you are satisfied with how your complaint was handled;
  • be polite, efficient and fair in all of our dealings with you. 


This procedure explains what to do if you have a complaint about any of our services or products. It also outlines the timescales you should expect for resolving complaints and who to contact if you are not satisfied with our response. 


How and where to complain

If you are dissatisfied with any aspect of our service or products, there are several ways in which you can choose to raise a complaint. You can advise us in person, in the first instance by contacting your usual business contact. If the issue is not resolved you should write to the Complaints Officer as listed on the FCA Financial Services Register: https://register.fca.org.uk/

What we will do

We aim to resolve all complaints promptly and will acknowledge your complaint upon receipt. Our acknowledgement will outline the steps we propose to take in order to resolve your complaint. Sometimes, due to the nature of the issue we will need time to investigate it, but we will keep you updated on our progress and the anticipated timescales for responding to you.

Where we are unable to resolve your complaint after three business days, we will write to you or email you to acknowledge your complaint and to explain the action that we intend to take and who will be dealing with your complaint.

What to do if you are unhappy with our response

If you are not satisfied with our final response, you have the right to take legal action if you consider this necessary.

Summary of NAB’s Conflicts of Interest Policy

Please familiarise yourself with NAB’s Conflicts of Interest Policy.

Information on risks, costs and charges for financial instruments offered from NAB London

Please familiarise yourself with the information (including Risks, Costs and Charges) related to the MiFID II regulation.

  • MiFID II General Information Regarding Risks Costs and Charges (PDF, 300 KB)

Coming up

The following relevant information will be made available by the highlighted dates as we progress towards the implementation date for MiFID II:

  • Best Execution Reporting under MiFID II RTS 28 – April 2018
  • Best Execution Reporting under MiFID II RTS 27 – June 2018

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