The former National Provincial and Union Bank of England, Waterloo Station


The rebuilt station was formally opened on 21 March 1922 by Queen Mary. The main pedestrian entrance, the Victory Arch (known as Exit 5), was designed by James Robb Scott and is a memorial to company staff who were killed during the war. Upon opening, it marked 585 employees who had been killed in World War I.

From Wikipedia:

Tournier v National Provincial and Union Bank of England

In 1924 the bank was involved in a notable court case. In England and those common law jurisdictions whose approach follows that of English law in treating the duty of confidentiality as resting in contract, the classic authority is the Court of Appeal decision in Tournier v National Provincial and Union Bank of England. The duty extends at least to information concerning account transactions and extends beyond the date of the termination of the banker customer contract. Information attained from other sources, such as a credit reference agency, is also covered. The duty is not absolute for the bank may disclose information where the disclosure is under compulsion by law, where there is a duty to the public to disclose, where the interests of the bank require disclosure and where the disclosure is made by the express or implied consent of the customer.”

Anna Modestou wrote at The Legal Compass on Nov 12, 2020 an 8 min read entitled The Duty of Confidentiality in Banking: is Tournier long gone?:

“…The case concerned Mr Tournier, who overdrew his bank account by a sum of 10 pounds, and agreed to pay monthly instalments as repayment. After Mr Tournier’s initial commitment towards his liabilities, a remaining sum of 6 pounds was due. The bank’s officer noticed that a cheque issued from Mr Tournier’s employer towards Mr Tournier had not been deposited to the aforementioned individual’s overdrawn account but to that of a third person. Investigating the issue further, the bank officer discovered that the third account belonged to a bookmaker. Frustrated with the discovery, the bank officer communicated the information to Mr Tournier’s employer, who was also a customer to the bank, to settle the overdraft. Mr Tournier’s employer, concerned with the fact that his employee might not be a trustworthy gentleman, but a gambler, decided not to renew the employment contract that was under provisional conditions with the view of a future permanent position. Based on this loss suffered, Mr Tournier sued the bank...


It is evident that the duty of confidentiality has been considerably eroded due to the heavy injections of exceptions where disclosure is available without any liability burdening the bank’s side, if each legal regime’s requirements introducing such exceptions are fulfilled thoroughly. This was inevitable as the imperatives of modern life demanded the decisive treatment of phenomena which excessively grew in the context of confidentiality, but also emerged rather naturally since Tournier itself has made clear from the beginning that the confidentiality duty is not absolute, but inherently contains qualifications based both on public policy and private law considerations. The heavy documentation that banks have undertaken as part of their general practice and policy in order to fully preserve their interests, but also to save time and money might have stretched the duty’s boundaries, but have not displaced Tournier. In the absence of the codification of the duty its roots are still found in common law, and common law as it currently stands is represented by the celebrated decision. Thus, the decision in Tournier remains significant to the customer-bank relationship to the degree that it provides the principle behind any start of discussion about confidentiality in the banking sector.”

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s