The Information Commissioner’s Office has confirmed in press briefings that following a complaint made by BTU it’s in discussions with Lloyds regarding the data trawl of 36,000 staff personal accounts last year.
Members will recall the data trawl was used by Lloyds and its inhouse staff unions – Accord and Unite – to justify its pay increases for 2026 and 2027. Accord is now pretending it didn’t support what Lloyds did because it lost hundreds of members and was heavily criticised by its members. At the time data trawl was exposed by BTU, Accord’s General Secretary said the data was “helpful” and “interesting”.
Lloyds staff will never forget those words and nor will we.
In our letter dated 18th November 2025 to Mr. John Howard, the Information Commissioner, we said:
“In defending its decision to trawl through 36,000 staff accounts, Lloyds said:
“In these situations, any insights used are always aggregated and anonymised to ensure both compliance with important data protection regulations and to support out common practice of using data to underpin our decision making”.
Lloyds also said that it relied on ‘Legitimate Interest’ as its lawful basis for processing the data.
However, the fact that the data were aggregated and anonymised does not mean that those activities are exempt from the Data Protection Act. The data was taken from the personal accounts of employees and their spouses or partners without their express permission. Lloyds had no reason to access that data other than to justify its proposed pay increase. That’s not a legitimate reason under the Data Protection Act. The information was personal, non-employment based data, the collation of which wasn’t necessary to determine financial resilience. That could have been determined through less intrusive means. If Lloyds wanted to know whether its staff were resilient financially then it could have asked them directly. It chose not to do that. The data it processed served its interests and not those of its employees.
We consider this to be a major breach of the Data Protection Act that needs to be investigated as a matter of priority.”.
We produced two letters for members and their spouses/partners to send to Lloyds complaining about its decision to trawl through their personal accounts. Hundreds of members sent those letters, but they’ve had no response from Mr. Charlie Nunn or Lloyds.
Lloyds says that it will update complainants in 4 weeks if it’s still investigating their complaint. Complainants can expect to get a final response from Lloyds within 8 weeks. Members haven’t been updated yet and the 4-week period finishes later this week. We’ll produce a letter for members to refer their complaints to the Financial Ombudsman Service if they don’t get a response from Lloyds this week.
The Information Commissioner has also told us members can make individual complaints regarding the data trawl. We will be writing to members shortly on this.
We will be returning to this issue again in our next Newsletter. In the meantime, members with any questions can contact the Union’s Bedford Office on 01234 262868 (Choose Option 1).
MEMBERS SHOULD PASS THIS NEWSLETTER ON TO THEIR COLLEAGUES IN HALIFAX & LLOYDS SO THEY TOO CAN BENEFIT FROM THE ONLY INDEPENDENT TRADE UNION IN LLOYDS BANKING GROUP.