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Privacy Policy for Staff and Prospective Staff

LINX holds the personal data of those people it interacts with in line with appropriate privacy policies. Different policies apply depending on the context in which LINX interacts with you. These have been developed to comply with the principles of the GDPR

How Your Data is Used by LINX

This statement explains how The London Internet Exchange Limited (“LINX”, “we” and “our”) handles and uses data we collect about our employees and applicants for employment (“you” and “your”). In broad terms, we use your data to manage the employment relationship between LINX and you, including keeping in touch with you, keeping up to date on you and your needs and activities and how we are meeting these.  If your application for employment does not succeed not all of this will apply to you.

We will retain your data until the later of you leaving LINX’s employment or you request us to do otherwise. Even after you have left LINX, we will retain certain data which we are obliged to keep for legal purposes. When changes are made to this statement, we will publish the updated version to our website and notify you by other communications channels as we deem appropriate or necessary.

The controller for your personal data is the London Internet Exchange Ltd, Trinity Court, Trinity Street, Peterborough, PE1 1DA, United Kingdom. The person responsible for data protection at the time of issue, and the person who is responsible for monitoring compliance with relevant legislation in relation to the protection of personal data, is Malcolm Hutty. You can contact us in this regard by emailing dataprotection@linx.net.

The legal basis for processing your personal data is that it is required to administer your contract of employment with LINX or its subsidiary companies, except where elsewhere in this statement we have indicated otherwise. You may ask us to explain our rationale at any time.

We collect and process your personal data, as specified below, for a number of purposes, including:

  • to contact you in connection with your employment;
  • to provide HR and Financial services in connection with your employment eg. medical insurance, pension provision, holiday administration and remuneration;
  • to advise you of events and activities in connection with your employment;
  • to keep employment records eg. appraisal reports, salary and bonus history and performance management records;
  • providing information to government and other authorities about you as required by law;
  • providing information to third parties to carry out security screening, interpreting and holding the information gathered;
  • where third parties legitimately provide us with information, we shall retain this eg. information provided by employment agencies, information provided by government agencies such as your tax code and any attachment to earnings;
  • We may also provide your details to third parties to carry out administration functions eg. Selenity to administer expenses, HMRC;
  • We have subsidiary companies London Internet Trading Limited and LINX America Inc with whom we share your data. LINX America Inc operates in the USA.

Note:

  • The provision of your personal data was not part of a statutory obligation.
  • No decisions are automated within the scope/meaning of the GDPR.

Your Rights

You have the right: to ask us for access to, rectification or erasure of your data; to restrict processing (pending correction or deletion); to object to communications or direct marketing; and to ask for the transfer of your data electronically to a third party (data portability). Some of these rights are not automatic, and we reserve the right to discuss with you why we might not comply with a request from you to exercise them.

Where your personal details were supplied by a third party or taken from publicly accessible sources you have the right to be informed of the source.

Where you opt out of all future communications or exercise your right to erasure, we may continue to maintain a core set of personal data (name, address, email addresses) to ensure we do not contact you inadvertently in future.

You retain the right at all times to lodge a complaint about our management of your personal data with the Information Commissioner’s Office at https://ico.org.uk/concerns/.

Updated 3 July 2023

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