Recruitment Privacy Policy

This privacy policy was last updated on 8 June 2022.

1. Introduction

Learnosity is committed to protecting the privacy of your personal data provided to us in recruitment processes. We believe it’s important that you understand how Learnosity uses your personal data during its recruitment activities, and what rights you have in relation to such data. This is a notice of privacy practices, not a contract or agreement.

This privacy notice sets out how the Learnosity processes personal data provided to us when considering applicants for employment or contracting. It applies to all companies within Learnosity:

  • The Learnosity division, comprising Learnosity Limited (Ireland), Learnosity Pty. Ltd (Australia) and Learnosity Inc (US) and any other Learnosity-affiliated companies in the future.
  • The Questionmark division, comprising Questionmark Computing Limited (UK), Questionmark Corporation (US) and Questionmark GmbH (Germany) and any other Questionmark-affiliated companies in the future.

Different policies apply for the Learnosity’s processing of personal data provided to us for other purposes. For the general privacy notices aimed at customers and website users, see for Questionmark division –; for Learnosity division –

Learnosity has legitimate interests in processing personal data of applicants to make recruitment decisions, which we balance against applicants’ interests and rights to privacy. Learnosity will always process your personal data in accordance with applicable laws. You should read this privacy notice carefully and contact us with any questions before providing us with personal data.

2. Information we may collect from you during the application process?

During the application process, we will request various information including personal details, contact information, qualifications, and experience and may conduct interviews and engage in correspondence with you. In some Learnosity teams, we use assessments to help determine job fit, in which case we will ask you to take such assessments.

You don’t have to provide what we ask for, but it might affect your application in some jurisdictions if you don’t.

3. Information we may collect after making a job offer to you

If we make an offer of employment or contracting, we will ask you for information so that we can carry out pre-engagement checks. These pre-engagement checks vary by jurisdiction but may include references from prior employers, identity confirmation, proof of right to work in the jurisdiction you are being engaged in, and criminal or other background checks. We use third-party processors to do such checks, consistent with applicable laws. You do not have to agree to these checks but in most jurisdictions, it’s likely that your offer of employment or contracting will be conditional on them.

4. How we store and use your personal data

Learnosity has in place appropriate technical and organizational measures to protect the security of personal data we process, including that of recruitmentapplicants. Learnosity has assigned specific responsibilities to address privacy and security related matters and enforces our internal policies and guidelines through an appropriate selection of activities, including proactive and reactive risk management, security and privacy training and assessments. Learnosity will process applicant’s personal data according to technical and organization measures that meet the general principles of ISO 27002 and ISO 27001 Please be aware that due to the inherent nature of the internet, there is no guarantee that emails are secure and all emails and internet transmissions are sent at the user’s own risk.

Learnosity is an international group of companies and any information you share with us will be processed internationally including in the US, Europe/UK and Australia and sometimes in other countries outside the European Economic Area (EEA). We ensure that any personal data originating within the EEA/UK that is transferred to or accessed from outside of the EEA/UK is processed via an acceptable mechanism under European/UK data protection law, for example by having appropriate contractual clauses in place with those we pass it to, to ensure a comparable level of protection for your personal data. We can share copies of these clauses on request.

Due to shared systems and personnel within Learnosity, personal data processed during recruitment processes may be shared with or accessible to affiliated entities under Learnosity common ownership.

We will use the contact details you provide to us to contact you to progress your application. We use your personal data for purposes of our legitimate interests in relation to considering you for a position, including:

  • evaluating your suitability for the role you have applied for;
  • People and Culture recruitment recordkeeping;
  • ensuring compliance with applicable laws;
  • and conducting pre-engagement and background checks, as described above.

The information you provide during the process will only be used for the purpose of reviewing your application, considering you for another job role, or to fulfil legal or regulatory requirements if necessary.

5. Use of third parties

We use third-party processors to record information during the recruitment process. Third parties are required to keep your data confidential. We will not share any of the information you provide during the recruitment process with any third parties for marketing purposes.

We may also share personal data in response to a subpoena, court order, or legal process, to the extent permitted and required by law; to protect your security or the security of other persons including for national security or law enforcement purposes, consistent with applicable law; or in connection with a sale, joint venture or other transfer of some or all of the assets of Learnosity companies, provided that the acquirer commits to using personal information in a manner consistent with applicable law.

From time to time, we also work with recruitment agents, who operate under their own terms of service. If you are submitting an application via a recruitment agent, please also check their privacy notice as we do not necessarily control what they do with your personal data or how long they keep it. Processing of your personal data by a recruitment agent is outside the scope of this privacy notice.

6. Retention of data

Learnosity will only retain your personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable law.

If you apply for a position but we do not take you on as an employee or contractor, we keep the personal information you provide us as part of your application for a period of around two years, in case it is needed for legal purposes or in case we want to re-approach you or you re-apply.

If you join us as an employee or contractor, we keep information gathered during the recruitment process indefinitely while you remain engaged by us. When you join, or before if you request it, we will share with you our employee privacy notice which explains how we handle your personal data as a Learnosity employee or contractor and after you leave.

If you want us to delete your personal data at any time, please request this to your People and Culture contact or by email to or If you are unsure which division of Learnosity you are engaged by, you can contact either of the email addresses above and your email will be forwarded to the right person for response. We will delete data received from applicants who we do not hire when requested, unless there is a legal requirement to keep it.

7. Seeing the data we hold about you

If you want to see a copy of the data we hold about you, we will share it subject to any legal restraints. Please make such requests to your People and Culture contact or by email to or If you consider that any data held about you is inaccurate, you can use the same procedure to request us to rectify it.

8. Automatic decision making

As part of its recruitment process, where a job role has mandatory requirements (e.g. right to work in a country), Learnosity does ask applicants a series of questions to confirm if such requirements are met, and if the requirements are not met, the application is not taken forwards. You may if you choose to answer such questions
positively and explain later on in the process your situation. Additionally if you have any questions or concerns about your answers to such questions or you believe that you may match a job notwithstanding your answers to such questions, please reach out to us at Learnosity does not use automated decision making in our recruitment process. All recruitment decisions are made by people.

9. Changes to our privacy approach

We from time to time update our privacy approach for recruitment to ensure we stay up to date with legal requirements and good practice. We will post any updated notice on our website at the same URL as this notice.

10. Questions or complaints

If you have any questions about our approach to handling your personal data, please raise these with your Learnosity People and Culture contact. If you have any questions beyond this or wish to raise a complaint, please reach out to us at or When contacting us with
any questions related to personal data, we will take reasonable steps to verify your identity before responding, which may include asking for proof of identification.

Country in which you are applying for a job openingData Controller of your personal dataAddress of the Data Controller
USAQuestionmark Corporation or Learnosity Inc (depending on entity you are engaged with)260 Madison Ave,
8th Floor,
New York, NY 10016,
United KingdomQuestionmark Computing LimitedNew Kings Beam House,
22 Upper Ground,
South Bank,
London SE1 9PD, UK
GermanyQuestionmark GmbHHopfenstr. 8,
80335, Munich,
IrelandLearnosity Limited6 Coke Lane,
Dublin 7, D07 EDP2,
AustraliaLearnosity Pty LtdLevel 18, 1 Margaret St, Sydney NSW 2000,

If you have any concerns under European data protection law, please reach out to or by email or send a letter by post to our addresses as above. If you are not satisfied with the response, then you may escalate your concerns and raise a concern with a European data protection authority. If your concern is with Learnosity Limited, you may raise it with the Irish Data Protection Commissioner, if your concern is with Questionmark Computing Limited, you may raise it with the Information Commissioner’s Office, and if your concern is with one of other Questionmark companies, you may raise it with the Bayerische Landesamt fur Datenschutzaufsicht (BayLDA).