Linksys Applicant Privacy Notice

Index

To help you find information quickly on any particular question you might have, we have set out an index below. Just click on the question you would like answered and you will be taken to the relevant section:
 
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Introduction and Definitions

The Linksys Group of Companies (including without limitation Linksys USA, Inc. and Linksys UK Limited) (each individually and collectively referred to in this Notice as “Linksys") has prepared this Applicant Privacy Notice ("Notice") for applicants applying to roles within Linksys. In connection with your application, we must process your personal data. We think that it is very important that you understand how we use your personal data, and we take our obligations in this regard very seriously. The purpose of this Notice is therefore to give you information about how Linksys collects, processes, stores and otherwise uses information about you, and your rights in relation to that information. Please read this document carefully. If you have any questions or need to access this Notice in an alternative format due to having a disability, please call us at 800-405-8760. Linksys needs to process your personal data in order to process your application for employment. There are also statutory requirements we must comply with in relation to your application. If we are not able to carry out the processing activities we describe in this Notice, we may not be able to continue with your application. We or our service provider need to ask for your specific consent to process your personal data in a particular way in certain circumstances, such as for the purpose of conducting background checks prior to you commencing employment with us, and to enable relevant third parties to release information about you as part of those checks. If we need to conduct a background check, we or our service provider will provide a consent form to confirm you consent to us processing your data for the purposes of carrying out the background checks listed. Although we are seeking your consent in relation to certain background checks, you should note that in most cases we will process your personal data for the reasons set out in this Notice, and it won't be appropriate or necessary for you to provide consent as the legal basis for processing your personal data. 2 When we say "Linksys", "we" or "us" in this document, we mean the Linksys entity that you're applying to work for. In addition, you will see a number of references to the "Linksys Group", which includes all other Linksys entities globally. We may update this Notice from time to time, for example if we implement new systems or processes that involve the use of personal data. In this Notice you will see reference to "Data Protection Law" - that refers to any local, national or international laws, rules and regulations related to privacy, security, data protection, and/or the processing of personal data, as amended, replaced or superseded from time to time


What categories of personal data does Linksys collect about me?

"Personal data" means any information relating to you. Linksys will collect, process and use the following categories and types of personal data about you, which together will be referred to as “Applicant Data”
 
  • identification data, such as your name, citizenship, passport data, photo, drivers' licence information, national insurance number, health insurance and governmental retirement plan information and tax reference;
  • personal information, such as your date and place of birth, emergency contact details, and gender;
  • contact details, such as your home address, telephone number and email address;
  • education and work experience, such as contact details for your current/former employer, information about your educational background, your work experience and other experience;
  • other application data, such as the information included in your application form/CV;
  • information collected as part of the interview process, such as notes taken from your interview or information provided from recruitment agencies;
  • background check information, such as information obtained through reference checks and confirmation about your work/educational background.
 
In addition to the collection, processing and use of the Applicant Data, Linksys collects, processes and uses the following special categories of personal information about you which we describe as "Sensitive Applicant Data":
 
  • health and medical data, if permissible under local rules and regulations, such as information on disability;
  • criminal records data if required under local rules and regulations, information necessary to be provided to a governmental agency for purposes of a criminal background check;
  • race or ethnicity data such as information contained in your passport or other citizenship and right to work documentation, and information which you have voluntarily provided to Linksys;
  • sexual orientation data where this has been provided voluntarily to Linksys
  
California Disclosure:

For purposes of California law, Linksys may collect the following categories of personal information about 
you: 
 
  • Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, social security number, driver’s license number, passport number or other similar identifiers.
  • Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may include signature, physical characteristics or description, state identification card number, education, bank account number, and medical information.
  • Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical or mental handicap, etc.
  • Professional or employment-related information.
  • Non-public education information (as defined in the Family Educational Rights and Privacy Act).
  • Inferences drawn from any of the information listed above.

We may disclose all of the above categories of information to our affiliates, professional service organizations (such as auditors or law firms), and other service providers.

Additionally, we may collect the following categories of sensitive personal information (as defined under California law): passport data and/or driver’s license number, racial or ethnic origin, and sexual orientation. This information is collected in order to process your application for employment and to comply with our legal obligations. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121.

We do not “sell” or “share” personal information for purposes of cross-context behavioral advertising. To the extent we maintain and use personal data in a deidentified form, we will not attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy our legal obligations.


Why does Linksys need to collect, process and use my Applicant Data and Sensitive Applicant Data and what is the legal basis for doing so?

We collect and use Applicant Data and Sensitive Applicant Data for a variety of reasons linked to processing your application for a role with us (the "Processing Purposes").

To give you the full picture, we have set out each of the reasons why we collect and use Applicant Data, i.e., the Processing Purposes, and mapped these against the different legal bases that allows us to do so.

 
Processing PurposesLegal Bases
1. Administering and processing your application (including processing a job offer should you be successful) including identification data, contact details, information about your qualifications and employment history, and information obtained during your interview and information contained in your CVProcessing Purposes 1 to 3
  • Linksys’ legitimate interest in ensuring 
    efficient staffing operations; 
  • Compliance with legal obligations 
    which Linksys is subject to in relation 
    to employment law; an
  • Your consent as the data subject
    (specifically for background checks).

     
2. Determining your eligibility for the role you applied for, including identification data, contact details, information about your work and education experience, information obtained during your interview and information contained in your CV. 
3. Conducting background checks as part of your application, including identification data, contact details, information about your qualification and employment history. 
4. Complying with applicable laws and employment-related requirements along with the administration of those requirements, such as income tax, national insurance deductions, and employment and immigration laws which involves the processing of identification data and contact details.Processing Purposes 4 to 5:
  • Compliance with legal obligations which Linksys is subject to, particularly in relation to tax law, employment law, social security law 
    and immigration law.

     
5.  Monitoring and ensuring compliance with  applicable policies and procedures and laws,  which involves the processing of your identification data and contact details, including the operation of  a whistleblowing hotline. 
6. Communicating with you, Linksys employees and third parties, including informing you of future opportunities with Linksys (such as existing or potential business partners, suppliers, customers, end-customers or government officials), including communicating future employment opportunities, which involves the processing of identification data and your contact details.Processing Purpose 6:
  • Linksys’ legitimate interest in communicating with you in order to enter into an employment agreement with you; and
  • Compliance with legal obligation to which data controller is subject.
7. Responding to and complying with requests and legal demands from regulators or other authorities in or outside of your home country which involves the processing of identification data and contact details.Processing Purpose 7:
  • Compliance with legal obligations which Linksys is subject to
8. Complying with corporate financial responsibilities, including audit requirements (both internal and external) and cost/budgeting analysis and control which involves the processing of identification data, contact details, information about the role you have applied for, including the role's salary and benefitsProcessing Purpose 8
  • Linksys’ legitimate interest in ensuring that we manage our business effectively; and
  • Compliance with legal obligations which Linksys is subject to.

Below are the Processing Purposes and corresponding Legal Bases for Sensitive Applicant Data:
 
Processing PurposeLegal Bases
9. To accommodate your application and interview and for compliance with legal obligations, we may use health and medical data.Processing Purpose 9:
  • Your explicit consent as allowed by local data protection law; and
  • Necessary to carry out the obligations and to exercise specific rights of Linksys or you in the field of employment and social security and social protection law as permitted by local data protection law.
10, Criminal records background checks if required under local rules and regulations, may involve information necessary to be provided to a governmental agency for purposes of a criminal background check.Processing Purpose 10:
  • Your explicit consent as allowed by local data protection law;
  • Necessary to carry out the obligations and to exercise specific rights of Linksys or you in the field of employment and social security and social protection law as permitted by local data protection law; and
  • Necessary for reasons of substantial public interest as permitted by local data protection law.
11. Equal opportunities monitoring and diversity monitoring and initiatives may involve us using race or ethnicity data such as information contained in your passport or other citizenship and right to work documentation, or sexual orientation data where this has been provided voluntarily to Linksys.Processing Purpose 11:
  • Necessary for reasons of substantial public interest as permitted by local data protection law; and
  • Your explicit consent as allowed by local data protection law.

Who might Linksys share my personal information with?

As you may know, we are part of the global Linksys Group, and several entities in this group are involved in the Processing Purposes. To ensure that the Processing Purposes can be completed, your information may be shared with any of the entities within the Linksys Group network. Where we do share data in this way, however, it is our policy to limit the categories of individuals who have access to that personal information. Linksys may transfer personal data to affiliated and unaffiliated entities, including to entities within and outside the Linksys Group, for the Processing Purposes as follows:
  • Within the Linksys Group. As the Linksys entity that you are applying to is part of a wider group headquartered in California, United States with offices located across the globe, which all partially share management, human resources, legal, compliance, finance and audit responsibility, Linksys may transfer the Applicant Data and Sensitive Applicant Data to, or otherwise allow access to such data by other entities within the Linksys Group.
  • Regulators, authorities, and other third parties. As necessary for the Processing Purposes described above, personal information may be transferred to regulators, courts, and other authorities (e.g., tax and law enforcement authorities), independent external advisors (e.g., auditors), insurance providers, pensions and benefits providers, internal compliance and investigation teams (including external advisers appointed to conduct internal investigations). We may also disclose personal information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws.
  • As needed to establish our rights or exercise legal claims. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies.
  • Data processors. As necessary for the Processing Purposes described above, personal data may be shared with one or more service providers, whether affiliated or unaffiliated, to process personal information under appropriate instructions ("Data Processors"). The Data Processors may carry out instructions related to recruitment, background checks, right to work checks, criminal checks, workforce administration, IT system support and maintenance, payroll and compensation, training, compliance, and other activities, and will be subject to contractual obligations to implement appropriate technical and organisational security measures to safeguard the personal information, and to process the personal information only as instructed.
  • Acquisitions. If another company acquires, or plans to acquire, our company, business, or our assets, we may share personal information with that company, including at the negotiation stage.
  • Disclosures with Your Consent. We may ask to share your personal data with other unaffiliated third parties who are not described elsewhere in this Notice. For example, we may share your personal data with third parties to whom you or your representatives authorize us to disclose personal data.

For a full list of the Linksys Group entities and unaffiliated entities that we may share your data with, please contact us as set out below.

As you may expect, some of the recipients we may share Applicant Data and Sensitive Applicant Data with may be located in countries outside of the UK and Europe.

Some countries where recipients may be located already provide an adequate level of protection for this data (e.g. Canada and the United Kingdom). If recipients, including Linksys Group entities, are located in countries without adequate protections for personal data outside of the UK and EU, Linksys will be bound by the EU Standard Contractual Clauses pursuant to Article 46(2)(c) GDPR, which the European Commission has assessed as providing an adequate level of protection for personal data, to ensure that your data is protected adequately, or the International Data Transfer Agreement, which the Information Commissioner’s Office (“ICO”) has assessed as providing an adequate level of protection for personal data.

In all cases, Linksys will take the necessary measures to ensure that transfers out of the UK and EU are adequately protected as required by Data Protection Law. You can ask for a copy of the such appropriate safeguards by contacting us as set out below ("Who can I contact about this stuff?").


How long will Linksys keep my personal information for?

It is our policy not to keep personal information for longer than is necessary. We may, for example, keep your personal information for a reasonable time after your application process is completed, in case we have future job opportunities that we consider you are suitable for. Where personal information is kept, that period will be determined based on the applicable local law. For further information, please contact us as set out below to request further details on how long Linksys will retain different categories of personal information.


How does Linksys protect my personal information?

We maintain reasonable physical, technical, and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to help protect your personal information against loss, unauthorized access or disclosure, modification, or destruction. While we use reasonable efforts to protect your personal information, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any privacy or security event relating to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.


What rights do I have in respect of my personal information?

Depending on where you reside, you may have a number of rights in relation to your Applicant Data and Sensitive Applicant Data. These can differ by country, but can be summarised in broad terms as follows:

 
(i) Right of access

You have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. We do have to take into account the interests of others though, so this is not an absolute right, and if you want to request more than one copy, we may charge a fee.

(ii) Right to rectification

You have the right to rectify or correct inaccurate or incomplete personal data concerning you. We encourage you to review this information regularly to ensure that it is accurate and up to date.

(iii) Right to erasure (right to be forgotten)

You may have the right to ask us to erase personal data concerning you.

(iv) Right to restriction of processing

In limited circumstances, you may have the right to request that we restrict processing of your personal data, however our legitimate interest in processing Applicant Data and Sensitive Applicant Data may override a request that you make.

(v) Right to data portability

You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity.

(vi) Right to object and rights relating to automated decision-making

Under certain circumstances you have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us, and we may be required to no longer process your personal data. This may include requesting human intervention in relation to an automated decision so that you can express your view and to contest the decision.

Please note, not all these rights are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your requests. This may occur because the law permits or requires us to do so. To exercise any of these rights, please contact us as stated below (Who can I contact about this stuff?). If you disagree with how we handled a request, you may appeal our decision by contacting us with the subject line “Appeal.”

We will respond to your request promptly upon receipt. If you are in the UK or EEA, this will be within one month of receipt, or, if further time is required, we will inform you of this and the reason for the delay. We may ask you to verify your identity before we can act on your request. We may conduct an identity verification by phone call or email. Depending on your request, we may ask for information such as your name, address, or the date you submitted your application. We may also ask you to provide a signed declaration confirming your identity.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.

If you are an authorized agent submitting a request on behalf of an individual in California, you must attach a copy of a completed Authorized Agent Designation Form, located
here, indicating that you have authorization to act on the consumer’s behalf. If we do not receive this information, the request will be denied.

You also have the right to lodge a complaint with the competent data protection supervisory authority, which may vary depending on your location. Please click
here for a list of contact details for the EU data protection supervisory authorities. We do not discriminate against individuals who exercise state-conferred rights.

Who can I contact about this stuff?

If you have concerns or questions regarding this Notice or if you would like to exercise your rights as a data subject, you can contact us by filling out our webform located
here or get hold of the right person here:

Linksys USA, Inc.
121 Theory Irvine, California 92617

Linksys UK Limited (United Kingdom)
Unit 1, Regent Park, Booth Drive,
Park Farm South, Wellingborough,
Northamptonshire, NN8 6GR
United Kingdom

If you are in California, you can also contact us by phone at 800-405-8760.

If you are based in the EU, you may contact our Data Protection Representative, DataRep. You may do so by:

 
  • sending an email to DataRep at linksys@datarep.com,
  • contacting DataRep on its online webform located here, or
  • mailing your inquiry to DataRep at Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands. When mailing inquiries, please mark your letters for “DataRep” and not “Linksys”.
 
Please refer clearly to Linksys in your correspondence. If you have any concerns over how DataRep will handle your personal data, please refer to DataRep’s privacy notice located here. The contact details of the relevant individual within our Legal Department are as follows:
 


Additional Information for California Residents

California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, this section applies to you in addition to the rest of this Notice:

Below are the categories of Personal Information we collect. Note that we do not “sell” or “share” personal information about staff members (as such terms are defined under California law).

 

Categories of Personal Information CollectedCategories of Recipients to Whom Information is Disclosed for our Business Purposes
Identifiers, such as real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.
  • Affiliates or subsidiaries
  • Business partners
  • Government entities (as may be needed to comply with law or prevent illegal activity)
  • Internet service providers
  • Service providers
Other identifying information, such as physical characteristics or description, date of birth and signature.
  • Affiliates or subsidiaries
  • Business partners
  • Government entities (as may be needed to comply with law or prevent illegal activity)
  • Service providers
Health and safety information, such as health conditions (if relevant to your employment), job restrictions, workplace illness and injury information, and health insurance policy information.
  • Affiliates or subsidiaries
  • Government entities (as may be needed to comply with law or prevent illegal activity)
  • Service providers
Characteristics of protected classifications under California or federal law, such as age, race, color, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status to the extent disclosed by the staff member.
  • Affiliates or subsidiaries
  • Government entities (as may be needed to comply with law or prevent illegal activity)
  • Service providers
Sensory information, such as audio, electronic, visual, thermal, olfactory, or similar information. This may include call monitoring and video surveillance and in some cases COVID-19 or other public health related temperature checks.
  • Affiliates or subsidiaries
  • Government entities (as may be needed to comply with law or prevent illegal activity)
  • Service providers
Professional or employment-related information, such as work history, academic and professional qualifications, educational records, references, interview notes, job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records.
  • Affiliates or subsidiaries
  • Business partners
  • Government entities (as may be needed to comply with law or prevent illegal activity)
  • Service providers
Inferences drawn from any of the information listed above, such as profile or summary about an applicant's preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.
  • Affiliates or subsidiaries
  • Government entities (as may be needed to comply with law or prevent illegal activity)
  • Business partners
  • Service providers

Sensitive Categories of Personal Information

We collect the following categories of sensitive personal information (as defined under California law). Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.

 
Categories of Sensitive Personal Information Collected Purposes for which it is collected
Social security, driver’s license, state identification card, or passport number.
  • Comply with all applicable laws and regulations.
  • Conduct background checks (where permitted by applicable law)
  • Eligibility for employment
Racial or ethnic origin, religious or philosophical beliefs, or union membership.
  • Comply with all applicable laws and regulations.
Information concerning sex life or sexual orientation
  • Comply with all applicable laws and regulations.


Last Updated and Effective: March 2023

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