LinkedIn Global Data Privacy Notice for Job Candidates
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- Abner Reeves
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1 LinkedIn Global Data Privacy Notice for Job Candidates Issued: May Overview At LinkedIn, one of our core values is Relationships Matter, which speaks to the trust we strive to foster with our colleagues and partners. In line with this value, we have created this Global Data Privacy Notice to describe how we handle personal information about individuals applying for employment and other contingent roles at LinkedIn. We have a responsibility to protect and preserve the private information of every LinkedIn member, employee and job applicant. And we take this responsibility seriously. This document outlines 1) the personal information we collect and process 2) the purposes for which we do this and 3) your rights in connection with it. It covers all individuals applying for employment at LinkedIn, including applications for all types of contingent and non-permanent positions, such as agents, independent contractors, consultants, temporary contract workers, professional advisors and interns. We acknowledge it contains quite a bit of detail - it's a lot to take in! But the key takeaway is this: We respect your privacy rights and are committed to handling your personal information responsibly and in accordance with applicable law. Before reading on, let s define a few key terms. These terms have a specific meaning under the law and we want to be transparent and clear about what they represent. You ll see they are capitalized throughout the document: "LinkedIn", "we" or "us" - LinkedIn LinkedIn Group - LinkedIn Corporation and its parent company, Microsoft Corporation, subsidiaries and affiliates "Notice" - this Global Data Privacy Notice You Individuals applying for employment and other contingent roles at LinkedIn Personal Information - any information relating to an identified or identifiable natural person Data Controller - a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Information. A list of LinkedIn group companies that serve as data controllers is attached as Annex A. Please also be aware this Notice covers the handling of your Personal Information as a job candidate. It does not cover your use of LinkedIn products or services as a member, visitor or user. To learn more about our data collection practices in our products, please see the privacy policies linked to those products and services. If you have any questions about the privacy of your Personal Information or the details this Notice, contact HR-privacy@linkedin, which will put you in contact with our Legal Department contacts in both the US and Ireland, or to one of the following mailing addresses: For Candidates in the United States: LinkedIn Corporation Attn: Legal Department - Candidate Privacy Notice Issues 1000 West Maude Avenue 1
2 Sunnyvale, CA USA For Candidates outside the United States: LinkedIn Ireland Unlimited Company Attn: Legal Department - Candidate Privacy Notice Issues Wilton Plaza Wilton Place, Dublin 2 Ireland Happy reading! Your friendly neighborhood LinkedIn Legal Eagles 2. Types of Personal Information we collect During the application, recruitment and onboarding process at LinkedIn, we may process the following types of Personal Information about you (without limitation): Identification and contact details such as your name, address, telephone/ address. Educational and employment background such as academic and professional qualifications, CV/résumé and/or LinkedIn profile, transcripts and employment references. Job application information such as the roles for which you are applying, your job application and related documentation/communications, cover letters, information from interviews, compensation/benefits requests, relocation information, and any other information you provide to us in support of and during the recruitment process. National identifiers such as national ID/passport, immigration status, work authorizations, visas, social security numbers. Previous applications/roles: information relating to previous applications you have made to LinkedIn and/or any previous employment at LinkedIn. We also may collect information about you from third parties or public sources as needed to support the recruitment process. For example, before your employment or assignment with LinkedIn, we may collect information from social media sources including your LinkedIn profile for recruitment purposes. We also may conduct background screenings through a third-party vendor and collect information about your past education, employment, credit and/or criminal history (where permissible and in accordance with applicable law). Personal Information also includes Sensitive Personal Information which is any information that reveals your racial or ethnic origin, religious, political or philosophical beliefs, trade union membership, or information about your health/sex life. We may request, on a voluntary disclosure basis, limited Sensitive Personal Information such as racial/ethnic origin, disability status and gender for the purposes of government reporting obligations and/or ongoing equal opportunities monitoring. Also, if you choose to provide it, you can provide information about your disabilities so that we can arrange disability access during recruitment. In all cases, we will handle your Sensitive Personal Information in accordance with applicable laws. LinkedIn s use of Sensitive Personal Information varies by region and country. If you have questions about this, please contact us (see Section 9 for contact details). 3. Why we collect your Personal Information 2
3 We collect and use your Personal Information primarily for recruitment purposes in particular, to determine your qualifications for employment or a temporary assignment and to reach a hiring decision. This includes: assessing your skills, qualifications, background for a particular position; communicating with you during the recruitment process; verifying your information and carrying out reference checks or background checks (where applicable); making arrangements for your future employment; and generally managing and improving our recruitment and hiring processes. We also may use your Personal Information to comply with applicable laws and regulations, or to protect the rights and interests of LinkedIn, our users, employees, applicants and others, as required or permitted by applicable law. If you accept a job with LinkedIn, this will form part of your ongoing employment or contingent workforce record. If you are not successful, we may still keep your application to consider you for other suitable openings at LinkedIn in the future, unless you request deletion of your data. 4. Who we share your Personal Information with LinkedIn may share your Personal Information with the following third parties as necessary in connection with our recruitment process, your future employment, and other lawful grounds: (i) Disclosures to other group companies We may share your Personal Information with other affiliates, our parent company Microsoft Corporation, and subsidiary companies of the LinkedIn Group around the world in connection with our recruitment process and as outlined above. (ii) Disclosures to third party agents and service providers In addition, we make certain Personal Information available to third parties who provide services to us. We do so on a "need-to-know" basis, following applicable data privacy law. For example, we currently use Jobvite for recruitment software services. Also, some Personal Information will be available to our employee benefit plans service providers and third party companies such as payroll support services, verification/background checking services, or relocation support services. These service providers may change over time but we will always use trusted vendors who will handle your Personal Information in a manner consistent with this Notice and in accordance with applicable law. (iii) Disclosures to other third parties We may also disclose Personal Information to other third parties, including: To comply with our legal obligations, regulations or contracts, or to respond to a court order, administrative or judicial process, such as a subpoena or search warrant; In response to lawful requests by public authorities (such as national security or law enforcement); With your consent; 3
4 As necessary to establish, exercise or defend against potential, threatened or actual litigation; Where necessary to protect LinkedIn, your vital interests, or those of another person; or In connection with the sale, assignment or other transfer of all or part of our business. 5. Transfer of Personal Information abroad Because LinkedIn operates at a global level, we may need to transfer Personal Information to countries outside of where the information was originally collected. When we export your Personal Information to a different country, we will ensure that such data exports comply with applicable laws and legislation. 6. Data retention periods Personal Information will be stored only as long as is necessary for the purposes described in this Notice, to match you with prospective employment or assignment opportunities or as otherwise required by law, regulation or other legitimate business interests. If you do not want us to retain your data, please contact us at the address below. However, we may need to keep the information if required by law. If you become an employee of a LinkedIn Group company, this information will become part of your employment record. 7. Your data privacy rights In some regions (like the European Economic Area), you have the right to request access to your Personal Information, or to request correction, amendment or deletion of your Personal Information where it is no longer accurate or processed in violation of data protection laws. In certain circumstances, you also have the right to object to the processing of your Personal Information. To make a request, please use the contact details in Section 9 below. We will consider and act upon any such requests in accordance with applicable data protection laws. 8. Updates to this Notice This Notice may be updated periodically to reflect any necessary changes in our privacy practices. Where such changes materially affect your privacy rights, we will make a prominent note at the top of the Notice to indicate when it was most recently updated. We encourage you to check back at this website periodically in order to be aware of the most recent version of this Notice. 9. Contact details Please send any questions about this Notice to HR-privacy@linkedin.com (which is routed to LinkedIn Legal Department contacts in both the US and Ireland) or to one of the following mailing addresses: For Candidates in the United States: LinkedIn Corporation Attn: Legal Department - Candidate Privacy Notice Issues 1000 West Maude Avenue Sunnyvale, CA USA 4
5 For Candidates outside the United States: LinkedIn Ireland Unlimited Company Attn: Legal Department - Candidate Privacy Notice Issues Wilton Plaza Wilton Place, Dublin 2 Ireland 5
6 Annex A LinkedIn Corporation Data Controllers The LinkedIn Global Data Privacy Notices for Employees, Contingent Workers and Job Candidates are issued by the following list of LinkedIn Group data controllers. Your data controller is typically the company to which you are applying, your direct employer or the company which is engaging your services, but may include parent companies as specified below. Australia: LinkedIn Australia Pty Limited Level 20, 60 City Road Southbank, Melbourne Victoria 3006 Australia 1 Martin Place Sydney NSW 2000 Australia LinkedIn Singapore Pte. Ltd. 10 Marina Boulevard Tower 2 Singapore Austria: LinkedIn Austria GmbH Eggenberger strasse 7 Graz A-8020 Austria Brazil: LinkedIn Representacoes do Brasil Ltda. Edifício Eldorado Business Tower Avenida Nações Unidas, Number th Floor, São Paulo, Brazil Canada: LinkedIn Technology Canada Inc. 250 Yonge St. Suite 2500 Toronto, ON M5B 2L7 Canada China: 6
7 Beijing LinkedIn Information Technology Co., Ltd. Jiaming Center No. 27, East Third Ring Road Beijing, China Building 18 #1 DiSheng Bei Road Beijing Yizhuang Development Area, China Shanghai International Commerce Centre Two ICC, Units , 22/F Huaihai Road West Section, Xuhui District Shanghai, China France: LinkedIn France SAS Rue du Rocher Paris, France Germany: LinkedIn Germany GmbH Hofstatt, 4th Floor Sendlingerstrasse 12 München, Germany Hong Kong: LinkedIn Hong Kong Limited Hysan Place 38th Floor 500 Hennessy Road Causeway Bay, Hong Kong India: LinkedIn Technology Information Private Limited Global Technology Park Tower A, 7 th Floor Devarabeesanahalli Village Varthur Hobli on Outer Ring Road Bangalore, India Maker Maxity, 3 North Avenue, 4th Floor Bandra-Kurla Complex, Bandra (East) Mumbai, India 7
8 17th Floor, Tower C Building # 5 (Cyber Terraces) DLF Cyber City Gurgaon, Haryana India Ireland: LinkedIn Ireland Unlimited Company Gardner House Wilton Plaza Wilton Place, Dublin 2 Ireland Italy: LinkedIn Italy S.R.L. Piazza Sigmund Freud, Milan, Italy Japan: LinkedIn Japan Ltd. Marunouchi Building Marunouchi 34th Floor, Office 7 Tokyo, Japan Netherlands: LinkedIn Netherlands B.V. Rembrandt Tower Amstelplein 1, 4 th Floor Amsterdam, Netherlands 1096HA Singapore: LinkedIn Singapore Pte. Ltd. 10 Marina Boulevard Tower 2 Singapore Spain: LinkedIn Spain, S.L. Paseo de la Castellana 202 5th floor, Madrid, Spain Sweden: 8
9 LinkedIn Sweden AB Birger Jarlsgatan Stockholm, Sweden United Arab Emirates: LinkedIn Middle East FZ-LLC Business Central Towers Dubai Media City, Tower A, 9 th Floor Dubai, UAE United Kingdom: LinkedIn Technology UK Limited Castlewood House New Oxford Street London, WC1A 1DG UK United States: LinkedIn Corporation 1000 West Maude Avenue Sunnyvale, CA USA All locations: *LinkedIn Corporation 1000 West Maude Avenue Sunnyvale, CA USA *Microsoft Corporation One Microsoft Way Redmond, WA USA *Transfers to parent companies are to facilitate the management of employment-related activities across the wider corporate group, including but not limited to: Management of employment records; Creation and administration of equity and other benefits; Compensation; Cross-company recruitment; Staff travel; Compliance with applicable laws and regulations, company/group policies and enabling intra-company investigations of employment-related activities; Staff career development (including evaluations, promotions/demotions and disciplinary matters) of employment related activities ; 9
10 Enabling intra-company communication, contact and collaboration of employment and business related activities; Provision of training and learning services for employment related activities; Administration of staff IT support and services for employment related activities; Company security for employment related activities; Management reporting and analysis of employment-related activities. 10
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