We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.
We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California applicants, we are subject to the California Applicant Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible as a “controller” of that personal information for the purposes of the GDPR. We are responsible for your personal information as a “business” under the CCPA/CPRA.
1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | N LiNK Consulting, LLC |
| Personal information | Any information relating to an identified or identifiable individual. |
| Special category personal information | Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation. |
| Sensitive Personal Information | Personal information revealing a applicant’s social security number, driver’s license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning an applicant’s health, sex life, or sexual orientation, contents of an applicant’s mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, or citizenship and immigration status. |
| Biometric Information | An individual’s physiological, biological, or behavioral characteristics, including information pertaining to an individual’s deoxyribonucleic acid (DNA), that is used or is intended to be used singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information. |
2. Personal Information We Collect About You. We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular applicant or household:
| Categories of Personal Information | Specific Types of Personal Information Collected |
| Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) | Legal name, alias, residential address, unique personal identifier, IP address, email address, telephone number, fax number, account name, social security number, driver’s license number, passport number, US immigration status, US visa number, or other similar identifiers |
| Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | His or her name, signature, social security number, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, any financial information, medical information, health insurance information, or criminal background information. |
| Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account | Account log-in, or credentials allowing access to an account. |
| Characteristics of protected classifications under California or federal law. | |
| Commercial information (e.g., records of private property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) | Employment history information. |
| Biometric information | n/a |
| Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding an applicant’s interaction with an Internet Web site, application, or advertisement) | Browsing history, search history, and information regarding an applicant’s or applicant’s interaction with an Internet Web site, application, or advertisement |
| Geolocation data | Location of past and present employers. |
| Audio, electronic, visual, thermal, olfactory, or similar information | Recording of the interview with an applicant and employer. |
| Professional or employment-related information | Educational documents such as copy of diplomas, transcripts, name, address, email, telephone, and fax of applicant’s past employers. |
| Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA) | Diplomas, degree certificates, transcripts, or any other education related documents. |
| Inferences drawn from any of the information identified above to create a profile about an applicant reflecting the applicant’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | Applicant’s preferred employment conditions, preferred profile of job candidates, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes |
| Racial or ethnic origin, religious or philosophical beliefs, union membership, or citizenship or immigration status | Racial or ethnic origin, religious or philosophical beliefs, union membership, existence of union in the employer’s business, citizenship, or immigration status. |
| Contents of an applicant’s mail, email, and text messages unless the business is the intended recipient of the communication | Contents of an applicant’s mail, email, and text messages if appropriate for the employment consideration. |
| Genetic data | n/a |
| Processing of biometric information for the purpose of uniquely identifying an applicant | n/a |
| Health information | Result of a medical exam. |
| Sex life or sexual orientation | Sex at birth, current sex, or sexual orientation if the employer needs accommodation. |
If you do not provide personal information required to provide our services to you, it may delay or prevent us from providing our services to you.
3. How Your Personal Information is Collected. We collect personal information from the following categories of sources:
- You, directly in person, by telephone, text, or email and/or via our website and apps
- Third party with your consent (e.g., your bank)
- Advertising networks
- Internet service providers
- Data analytics providers
- Government entities
- Operating systems and platforms
- Social networks
- Data brokers
- Publicly accessible sources (e.g., property records)
- Cookies on our website
- Our IT and security systems, including:
- Door entry systems and reception logs
- Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems –and–
4. How and Why, We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:
- To comply with our legal and regulatory obligations
- For the performance of our contract with you or to take steps at your request before entering into a contract
- For our legitimate interests or those of a third party –or–
- Where you have given consent
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
| What we use your personal information for | Our reasons |
| To provide services to you | For the performance of our contract with you or to take steps at your request before entering into a contract |
| To prevent and detect fraud against you or your potential employers | For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you |
| Conducting checks to identify our applicants and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal, and regulatory obligations that apply to our business, e.g., under health and safety regulations or rules issued by our professional regulator | For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you |
| Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, e.g., policies covering security and internet use | For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, training, and quality control | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, e.g., in relation to our financial performance, applicant base, product range or other efficiency measures | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
| Preventing unauthorized access and modifications to systems | For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations |
| Updating and enhancing applicant records | For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our applicants about existing orders and new products |
| Statutory returns | To comply with our legal and regulatory obligations |
| Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
| Marketing our services and those of selected third parties to: Existing and former applicantsThird parties who have previously expressed an interest in our servicesThird parties with whom we have had no previous dealings | For our legitimate interests or those of a third party, i.e., to promote our business to existing and former applicants |
| Credit reference checks via external credit reference agencies | For our legitimate interests or those of a third party, i.e., to ensure our applicants are likely to be able to pay for our products and services |
| External audits and quality checks, e.g., for ISO or Investors in People accreditation and the audit of our accounts | For our legitimate interests or a those of a third party, i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations |
For EEA Data Subjects: The above table does not apply to special category personal information, which we will only process with your explicit consent.
5. Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone, or post) about our services, including exclusive offers, promotions, or new services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and never share it with other organizations for marketing purposes without your written consent.
You have the right to opt out of receiving promotional communications at any time by:
- Contacting us at nlc@nlinkconsulting.com
- Using the “unsubscribe” link in emails or “STOP” number in texts or
- Updating your marketing preferences on our link to preference center
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
6. Who We Share Your Personal Information With. We routinely share personal information with:
- Potential employers
- Our affiliates
- Service providers we use to help deliver our services to you, such as payment service providers, warehouses, and delivery companies
- Other third parties we use to help us run our business,
- Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
- Third parties that check your background including credit reporting agencies
- Our insurers and brokers
- Our bank[s]
- [Other]
We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g., in relation to ISO accreditation and the audit of our accounts.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We may share some personal information with potential employers with your consent.
7. Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose:
- Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information
- Characteristics of protected classifications under California or federal law
- Professional or employment-related information
- Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)
- Inferences drawn from any of the information identified above to create a profile about an applicant reflecting the applicant’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes –and–
- Sensitive personal information
8. How Long Your Personal Information Will Be Kept. We will keep your personal information while we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf
- To search a candidate for a position that an employer seeks to hire
- To show that we treated you fairly –or–
- To keep records required by law
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. Generally, we will retain an applicant’s information until the applicant asks to delete it.
9. California Applicants: Your Rights Under the CCPA/CPRA. You have the right under the California Applicant Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:
| Disclosure of Personal Information We Collect About You | You have the right to know, and request disclosure of: The categories of personal information we have collected about you, including sensitive personal informationThe categories of sources from which the personal information is collectedThe categories of third parties to whom we disclose personal information, if any –and–The specific pieces of personal information we have collected about you Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retainedReidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or–Provide the personal information to you more than twice in a 12-month period |
| Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose | In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and–The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information. To opt-out of the sale or sharing of your personal information, please contact nlc@nlinkconsulting.com |
| Right to Limit Use of Sensitive Personal Information | You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to: Perform the services expected by an average applicant who requests those servicesTo perform the following services: (1) Helping to ensure security and integrity to the extent the use of the applicant’s personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of an applicant’s current interaction with the business, provided that the applicant’s personal information is not disclosed to another third party and is not used to build a profile about the applicant or otherwise alter the applicant’s experience outside the current interaction with the business without the applicant’s consent; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing applicant service, processing verifying applicant information, providing services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service that is owned or controlled by the business, and to improve, upgrade, or enhance the service that is owned or controlled by the business –and–As authorized by further regulations You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. To limit the use of your sensitive personal information, contact nlc@nlinkconsulting.com |
| Right to Deletion | Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records –and–Delete your personal information from our records –and–Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort Please note that we may not delete your personal information if it is reasonably necessary to: Complete the transaction for which the personal information was collected, provide a service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and usHelp to ensure security and integrity to the extent the use of the applicant’s personal information is reasonably necessary and proportionate for those purposesDebug to identify and repair errors that impair existing intended functionalityExercise free speech, ensure the right of another applicant to exercise his or her right of free speech, or exercise another right provided for by lawComply with the California Electronic Communications Privacy ActEngage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consentEnable solely internal uses that are reasonably aligned with your expectations based on your relationship with usComply with an existing legal obligation –or–Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information |
| Right of Correction | If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information. |
| Protection Against Retaliation | You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: Deny services to youCharge different prices or rates for services to you or to an employer, including through the use of discounts or other benefits or imposing penaltiesProvide a different level or quality of services to you –or–Suggest that you or your potential employer and employer will receive a different price or rate for goods or services or a different level or quality of services Please note that we may charge a different price or rate or provide a different level or quality of services to you, your potential employer, or employer, if that difference is reasonably related to the value provided to our business by your personal information. |
10. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
11. Changes to This Privacy Notice. This privacy notice was published on May 15th, 2024.
We may change this privacy notice from time to time–when we do, we will inform you via mechanism for informing the data subject of changes to the notice, e.g., our website or other means of contact such as email.
12. How to Contact Us. Please contact us by post, email, or telephone if you have any questions about this privacy policy or the information, we hold about you.
Our contact details are shown below:
13. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).
N LiNK Consulting, LLC: nlc@nlinkconsulting.com