What is recorded and which personal data is collected?
We record incoming and outgoing phone calls as well as online meetings with us that you participate in. These recordings capture your voice and other personal data that may be mentioned in the conversation.
Why do we record conversations?
Based on our legal obligation under GDPR Article 6 (1)(c) :
- To fulfil legal requirements related to investment services (such as MIFID II and Market Abuse regulations), for example when you buy or sell financial instruments like investment funds or stocks, or when we provide advice or other services related to financial instruments.
Based on our legitimate interest under GDPR Article 6 (1)(f):
We record and may listen to conversations for the purposes below. We have assessed that the processing of your personal data is necessary for these purposes and that our legitimate interests of doing so are not overridden by your interests or fundamental rights and freedoms. You always have the right to object to processing based on our legitimate interest.
- To document what we agreed on in the conversation, for example if we enter into an agreement for a product or service.
- To manage complaints, access requests, and to prevent and manage security incidents, fraud and threats.
- To assess Nordea’s compliance with internal and external rules in relation to compliance and risk management.
- In some countries, where permitted by law, we may use recordings for quality control of services delivered, employee training, and process improvement.
How are you informed about recording?
When contacting Nordea we will inform you if the conversation is being recorded. In certain instances, some incoming and outgoing conversations related to investment services may be recorded without prior notification. In such cases, you have previously been informed of the recordings as part of your contractual relationship with us.
If your consent is needed for the recording, we will inform you when we ask for your consent.
If you are invited to an online meeting, we will inform you about recording the meeting in the meeting invitation.
How long do we keep recordings?
Recordings related to investment services are legally required to be kept for five years from the date of the recording. If requested by authorities, that period can be extended to seven years.
Recordings are retained for ten years in accordance with Nordea Privacy Policy.
If a recording is kept for more than one purpose, the recording will be kept in accordance with the longest applicable retention time.
Your privacy rights
You have several rights in respect of the personal data we process about you. You have the right to:
- Request access to your personal data
- Request correction of incorrect or incomplete personal data
- Request erasure of personal data
- Request limitation of processing of personal data
- Object to processing based on our legitimate interest
- Withdraw consent
- Data portability.
Your request to exercise your rights will be assessed given the circumstances in each individual case.
If you wish to exercise your privacy rights you can do so by visiting our webpages, through your personal Netbank, by calling customer service or by visiting your local branch. Because we treat your personal data with the utmost care, we cannot act based on an email request and also cannot share, change or delete your personal data without confirming your identity through one of the channels mentioned above.
More detailed information about your rights is available in our Privacy Policy.