1. Who are Link Group?
The Link Group encompasses a large number of Link Group businesses based in UK, Europe, Australia, and its territories and in India. All the companies are wholly owned subsidiaries of Link Administration Holdings Limited (“Link Group”). When you apply for a career opportunity with the Link Group, you will be told at the application stage which Group business is recruiting and the country where the vacancy is located. For more information on Link Group, please visit www.linkgroup.com.
This Recruitment Privacy Notice (“the Notice”) governs the collection and use of personal data by Link specifically in relation to all candidates applying to become employees, staff, and contractors.
2. What is this Privacy Notice?
At Link we collect personal information about you and are committed to protecting this information and your privacy. Set out below is an explanation of how we use, collect, and safeguard your personal information. This Privacy Notice applies where any company within Link receives personal data through its website or from recruiters for recruitment purposes. We are committed to abiding by this Notice, as well as the requirements of applicable laws, throughout the entire recruitment process.
Candidates who are successful in their application and are formally offered employment with one of the companies within the Link Group will be provided with an Employee Privacy Notice as part of the on-boarding process which will supersede this Privacy Notice.
Personal data is any information relating to an identified or identifiable living person. When “you” or “your” are used in this statement, we are referring to the relevant individual who is the subject of the personal data.
In this Privacy Notice we refer to “processing your personal data”. Processing means anything that is done to or with personal data (including simply collecting, storing, or deleting that data).
3. Why do we collect your personal data?
We collect personal data about you during the recruitment journey. We cannot process your application for employment without your personal data. Our use of your personal data is based on a legitimate business interest we have in being able to consider and assess you for employment at Link Group.
4. What personal information do we collect?
We collect personal data about you as a candidate from different sources detailed below.
Information you give us - Our website.
As part of your use of our website you have the option on certain pages within this site to submit personal information to us by email, or online enquiry. To enable us to progress your application, we may ask you to provide the following personal information:
- Name, address, email address, telephone number, CV, work and education history, salary expectations and legal residency status which you provide us with on application to a role at Link Group.
- Date of birth, referee details, bank account details or other payment or financial information, medical details and other details related to background screening and commencement of employment with Link Group which you provide us with on accepting an offer of employment with Link Group.
- A record of any correspondence you have with us.
- Online identifiers including IP address and cookies.
- Information that may be found on sites such as LinkedIn, Xing and other professional networks which you may link to your profile in our system from time to time.
- Any reference, testing, assessment, or screening information collected with your consent from a 3rd party provider.
Information we collect about you.
We collect and process personal data about you during your application process, for example, our notes of your progress throughout the application process will contain your personal data.
Information we receive and collect from other sources.
We collect personal data about candidates for recruitment purposes from:
- Publicly available sources, including publicly available content on social media.
- Third parties such as recruitment consultants/agencies, vetting providers, and previous employers.
5. How we use your personal information?
We will use the information we hold about you for the following purposes:
- To consider and assess you for employment opportunities at Link Group.
- To check your identity and perform background screening checks prior to confirmation of employment.
- To manage a recruitment process including online and in-person assessments.
- So that we can communicate with you, as necessary.
- To notify you about your application and future opportunities at Link Group.
6. Who we share personal information with?
We will only disclose your personal information in accordance with applicable laws and regulations. We will disclose your information to the following third parties:
- Testing, assessment, and background screening providers in relation to your recruitment process with Link Group. In such cases we will only provide the minimum information required to perform the services.
- Any person with legal or regulatory power over us that may require disclosure on legal grounds/as permitted by law.
- Any member of the Link Group which means our subsidiaries, our ultimate holding company, and its subsidiaries (from time to time) as necessary to manage the recruitment process and consider you for employment opportunities within our Group.
Our legal basis for sharing your personal data with these third parties will be our legitimate interest or compliance with a legal obligation.
When processing your personal data, we will transfer this to our Human Resources operation in Australia. We may also transfer your personal data to third parties based in other countries. For example, some of these third parties (including Link Group subsidiaries and service providers) are located outside of the UK or the European Economic Area (EEA). Where data transfers take place, such transfers shall always be done in compliance with relevant data protection laws, e.g., we rely upon the Standards Contractual Clauses approved by the relevant Supervisory Authority such as the ICO. We will ensure that any such subsidiary or service provider has put in place adequate safeguards to ensure that your information is held securely and in accordance with this Privacy Notice. By submitting your personal data, you agree to the transfer, storing and/or processing of your information by these subsidiaries or service providers.
Link Group use a 3rd party Applicant Tracking System called Oracle HCM (Link Central Hiring Module) to manage our recruitment. In addition to the information contained in this Privacy Notice, your data will also be managed and protected according to the Oracle HCM Privacy Notice which you can find here: https://www.oracle.com/uk/human-capital-management
7. How do we keep your information secure?
We take protection of your personal information and our system security very seriously. Any personal information which is collected, recorded, or used in any way will have appropriate safeguards applied in line with our data protection obligations. We implement Internal and external audits and regular, independent assurance exercises across our business to ascertain the effectiveness of our security control environment and our security strategy. Your information is protected by controls designed to minimise loss or damage through accident, negligence, or deliberate actions. Our employees also protect your personal and confidential information whenever they are processing it and must undertake annual training on this. Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity, and availability of your information.
All exchanges of information between you and our recruitment team go through encrypted channels to prevent interception of your information. External access to your information via our recruitment system is protected by a login using your user ID and password. You should ensure that you keep these confidential. Additionally, all personal data is encrypted when exchanged between Link and third parties involved in processing your application for employment throughout the recruitment process.
You recognise that that your participation in the recruitment process is entirely at your own risk. Whilst Link has implemented high standards of security to protect personal data, Link websites are grouped to the internet, which is inherently insecure, Link cannot guarantee the information you supply will not be intercepted while being transmitted over the internet. Accordingly, Link has no responsibility or liability for the security of personal information transmitted via our website.
8. How long do we store your information for?
We generally hold your personal data on our systems for as long is necessary to assess you for current and short-midterm employment opportunities. This is ordinarily 12 months from your last contact with us or our last contact with you for employment with us unless you received employment with us through a recruitment agency when we would not hold your recruitment data for longer than 12 months. We will only retain your personal data after that if you are the successful candidate and the information will be used to on-board you and form part of your employment records.
When we no longer need to use your information, we will remove it from our systems and records and/or take steps to properly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with a legal or regulatory obligation).
9. Your rights
You have the following rights in relation to how we use your information. If you would like to exercise these rights, please contact us using the contact details listed in section 11 “Who can you speak to at Link about this Recruitment Privacy Notice?”
Right of access
You have the right to know if we are using your information and, if so, the right to access it and information about how we are using it. There will not usually be a charge for dealing with these requests. Your personal information will usually be provided to you in writing, unless otherwise requested. Where you have made the request by electronic means the information will be provided to you by electronic means where possible.
Right of rectification
We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case you have the right to require us to rectify any errors in the information, we hold about you.
Right to erasure
You have the right to require us to delete your information if our continued use is not justified. However, this will need to be balanced against other factors, depending upon the type of personal information we hold about you and why we have collected it, there may be some legal and regulatory obligations which mean we cannot comply with your request.
Right to restrict processing
In some circumstances, although you may not be entitled to require us to erase your information, you may be entitled to limit the purposes for which we can use your information.
Right of data portability
You have the right to require us to provide you with a copy of the personal information that you have supplied to us in a commonly used machine-readable format or to transfer your information directly to another controller (e.g., a third-party offering services competing with ours). Once transferred, the other party will be responsible for looking after your personal information.
Right to object to direct marketing
We may send information about roles we believe may be of interest to you, and you may choose to register for job alerts. You can unsubscribe from such job-based marketing at any time.
Right not to be subject to automated decision making and profiling
Link Group do not profile individuals however we use automated decision making to search candidates within our system who may have the relevant skills for other roles available.
The right to withdraw consent
For certain limited uses of your personal information, we may ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. If you withdraw your consent, we may not be able to provide certain products and services to you. If this is the case, we will tell you at the time you ask to withdraw your consent.
In some circumstances exercising some of these rights will mean we are unable to continue your recruitment process with the Link Group. It is important to understand that these rights are not absolute (e.g., their application may depend upon the legal basis we rely upon to process your personal data) and that we may require further information from you (e.g., to confirm your identity) to action your request.
10. Cookies and following links from our websites
- Technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login activity, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times, and download errors.
- Information about your visit, including the full Uniform Resource Locators (URL) clickstreams to, on and from our websites.
- Length of visit to certain pages, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page.
IP addresses and other online identifiers (i.e., those listed above) are your personal data. This means that you have the same rights under data protection laws in relation to these as you do with other personal data. For information about your rights see our cookies notice here: https://www.linkgroup.eu/policy-statements/cookies/
Our website and careers pages on SmartRecruiters may contain links to other sites. Such other sites may also make use of their own cookies and will have their own privacy policies. You should carefully review the privacy policies and practices of other sites, as we cannot control or be responsible for their privacy practices. We do not accept any liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.
11. Who can you speak to at Link about this Recruitment Privacy Notice?
Questions, comments, and the exercise of your rights regarding this Privacy Notice and your information are welcomed and should be addressed to the Data Protection Officer by email at firstname.lastname@example.org with subject “FAO Data Protection Officer” or by post at Data Protection Officer, Link Group, 65 Gresham Street, London EC2V 7NQ.
12. Your right to complain
If you wish to make a complaint on how we have handled your personal information, you can contact our Data Protection Officer. If you are not satisfied with our response or believe we are processing your personal information not in accordance with the law, you can complain to your relevant supervisory authority.
In the UK, the Information Commissioner’s Office (the “ICO”) is responsible for the implementation and enforcement data protection law. You have the right to complain to the ICO about our collection and use of your information. You can contact the ICO via their website – https://ico.org.uk/concerns/ - or by calling their helpline – 0303 123 1113.
In Ireland, the Data Protection Commission (“DPC”) is responsible for complaints handling, investigations, and enforcement for individuals. You have the right to complain to the DPC about our collection and use of information you can contact the DPC via their website - https://www.dataprotection.ie/en/individuals/exercising-your-rights/raising-concern-commission -or by calling them on 076 110 4800 or 057 868 4800.
13. Changes to this Privacy Notice
Please note that this Privacy Notice will be reviewed and may be changed from time to time. Any changes we may make to our Privacy Notice in the future will be posted on this page.
Updated April 2021