Opera Group Teamtailor Candidate Privacy Notice

Date Updated: 4th August 2026

Definitions

Career Site(s): A dedicated section of an Opera Group Company’s website where prospective candidates can view job vacancies, create a candidate profile, and submit applications for employment opportunities.

Data Controller: Any entity who is responsible for the decisions made about why and how they use Personal Data.

Data Processor: Any entity that is given the task of processing Personal Data by a Controller.

Data Protection Legislation: All applicable data protection and privacy laws in relevant jurisdictions, including but not limited to the Data Protection (Bailiwick of Guernsey) Law, 2017, the UK GDPR, the EU GDPR, the UK Data Protection Act 2018, and any other applicable data protection or privacy laws.

Opera Group Company: The Opera Group Companies relevant to this Candidate Privacy Notice are as follows:

• Opera Group Limited

• HFL Limited

• Accuro

• Meritus Trust Group Limited

• OAK Group

Personal Data: Any information that relates to an identified or identifiable living person.

Processing: Doing anything with personal data, including but not limited to collecting, storing, using, sharing, and deleting personal data.

Special Category Data: Personal data revealing an individual’s racial or ethnic origin, political opinion, religious or philosophical belief, trade union membership, genetic data, biometric data, health data, data concerning an individual’s sex life or orientation and criminal data.

Who We Are

Opera Group (“we”, “us”, “our”) operates through a number of Opera Group Companies who act as independent Data Controllers. This means that each Opera Group Company is individually responsible for deciding how they hold and use Personal Data.

The Opera Group Company responsible for the vacancy a Candidate applies for, or whose Career Site they connect with, will usually be the Data Controller of their personal data. Where a Candidate’s personal data is shared with another Opera Group Company for recruitment purposes, that company will act as an independent Data Controller in respect of any processing it carries out.

Overview

This Opera Group Candidate Privacy Notice (the “Privacy Notice”) applies to individuals who:

• Connect with us via one of our Opera Group Company Career Sites, to create a profile with us and receive information about current or future vacancies with us (you being a “Connecting Candidate”)

• Apply for a position with us, via one of our Opera Group Company Career Sites (you being an ”Applying Candidate”)

When we use the term “Candidate” in this Privacy Notice, we are referring to both Connecting Candidates and Applying Candidates unless it’s stated otherwise.

This Opera Candidate Privacy Notice outlines how we Process Candidate Personal Data during the recruitment process in accordance with relevant Data Protection Legislation. This Privacy Notice also describes what rights Candidates have when we process their Personal Data, and how they can exercise these rights.

The Personal Data We Process

We may Process different kinds of Personal Data in relation to Candidates, such as:

• Identifying Information. Including but not limited to: first name, last name, date of birth, nationality.

• Contact Information. Including but not limited to: telephone number, postal address, email address.

• Communications Data. We will collect and store Candidate communications with us, including any Personal Data provided in those communications.

• Professional Information. Including but not limited to: qualifications and skills, employment history, names of current and former employers, reference information, current salary and expectations, professional memberships.

• Right to Work Information. Including but not limited to: documentation evidencing a Candidate’s entitlement to work in the location of the relevant Opera Group Company.

• Reasonable Adjustments Information. Details of any reasonable adjustments that may be required. This information may, but not necessarily, include Special Category Data (see below) and will be processed in accordance with relevant anti-discrimination laws.

• Subscription Details. Details of which job update subscriptions Candidates have consented to receive in relation to Opera Group Companies.

• Additional Information. Any further information voluntarily provided during the recruitment process

• Special Category Data. During the recruitment process, we may also collect Special Category Data. Special Category Data requires higher levels of protection under Data Protection Legislation. We will only process this type of information where we have a lawful basis and, where required, an additional condition under applicable Data Protection Legislation.

Sources of Personal Data

We collect the Personal Data of Candidates from the following sources:

• Directly from the Candidate.

• From third parties, including recruitment agencies, referrals, referees, professional networking platforms (such as LinkedIn), publicly available corporate websites and other legitimate sources relevant to the recruitment process.

• When Candidates visit an Opera Group Company Career Site, certain technical information may be collected automatically, including IP address, browser type, device information, operating system, referral source and information relating to use of the Career Site.

• Where cookies or similar technologies are used on a Career Site, further information can be found within the relevant Opera Group Company website privacy notice and cookie notice.

Purposes of Processing and Legal Basis

We process Candidates’ Personal Data for the following purposes and under the following legal bases:

Purpose: To assess a Candidate’s skills, qualifications and suitability for the role

Legal Basis: Legitimate interest to ensure that Opera Group Companies can make informed hiring decisions and recruit suitable staff efficiently and lawfully

Purpose: To communicate with Candidates about the recruitment process

Legal Basis: Steps necessary prior to entering into a contract

Purpose: To carry out background checks and right-to-work verification

Legal Basis: Compliance with legal obligation

Purpose: To determine if any reasonable adjustments need to be made

Legal Basis: Compliance with legal obligation

Purpose: To keep records of the recruitment process

Legal Basis: Legitimate interest in ensuring fair and efficient recruitment

Purpose: To send job alerts, recruitment updates, or information about future vacancies where a Candidate has subscribed to receive them.

Legal Basis: Consent

Purpose: To consider a Candidate for future roles (where applicable)

Legal Basis: Consent, where separately obtained

Purpose: To facilitate, assess and review interviews, assessments or recruitment exercises

Legal Basis: Consent where recording is undertaken, and legitimate interest where processing is necessary to assess and manage the recruitment process.

In limited circumstances, interviews, presentations, assessments or recruitment exercises may be recorded for recruitment and assessment purposes. Candidates will be informed in advance and, where required by applicable law, their consent will be obtained before any recording takes place.

Purpose: To establish, exercise or defend legal claims arising from the recruitment process

Legal Basis: Legitimate interest and, where applicable, compliance with legal obligations.

We may retain and disclose Candidate Personal Data where reasonably necessary in connection with complaints, investigations, regulatory enquiries, litigation or the defence of legal claims.

Recipients of Personal Data (Data Sharing)

The Personal Data of Candidates may be shared with the following:

Regulators & Authorities (if required).We will share a Candidate’s Personal Data with regulators or authorities where we have a legal obligation to do so.

Third Parties. When Candidates connect with us via an Opera Group Company Career Site their Personal Data will be Processed by Third Party Service Providers acting as Data Processors, such as the supplier of our Group Company Career Sites and related applicant tracking system (see section on Third Party Processors for further information)

Where a Candidate’s Personal Data has been provided by a third party, such as a recruitment agency or referee, we may share limited Candidate Personal Data with that third party in connection with the recruitment process, only to the extent necessary.

Opera Group Companies. Where Candidate Personal Data is shared between Opera Group Companies, appropriate intra-group arrangements will be maintained to govern the sharing, security, retention and lawful use of that data. Depending on how a Candidate connects with us, different Opera Group Companies will have access to a Candidate’s Personal Data, as detailed below:

Opera Career Site

https://operagroup.teamtailor.com/

If a Candidate connects via the Opera Career Site the Personal Data submitted via their profile will be visible to Opera Group Company employees involved in recruitment and will be handled in accordance with Opera’s Privacy Notice. For further details on access restrictions, see the Data Security section below.

For each vacancy, the Opera Group Company offering the role will act as the Data Controller for the purposes of that application and their Privacy Notice will take effect.

A Candidate’s Personal Data may also be shared onwards with other Opera Group Companies, should the Candidate choose to connect with them via their individual Career Sites.

https://www.operalimited.com/privacy-policy

HFL Career Site

https://operagroup-hfl.teamtailor.com/

If a Candidate connects via the HFL Career Site the Personal Data submitted via their profile will be visible to employees of HFL Limited involved in recruitment and will be handled in accordance with HFL’s Privacy Notice. For further details on access restrictions, see the Data Security section below.

A Candidate’s Personal Data may be shared onwards with other Opera Group Companies, should they choose to connect with them via their individual Career Sites.

https://www.hfl.co.gg/privacy-policy

Oak Career Site

https://operagroup-oak.teamtailor.com/

If a Candidate connects via the OAK Career Site the Personal Data submitted via their profile will be visible to employees of OAK Group including, Oak Trust Guernsey Limited,

Oak Group (Bahamas) Ltd, Oak Management (Mauritius) Limited, Oak Global Shared Services Limited, Oak Group (Jersey) Ltd, Oak Group (IOM) Ltd involved in recruitment and will be handled in accordance with Oak’s Privacy Notice. For further details on access restrictions, see the Data Security section below. A Candidate’s Personal Data may be shared onwards with other Opera Group Companies, should they choose to connect with them via their individual Career Sites.

https://www.oak.group/pages/legals/privacy/

Third Party Processors

Opera Group Companies utilise the services of Third Party Processors to support the recruitment process via their Career Sites, including but not limited to:

Teamtailor - Our Career Sites are powered by Teamtailor. Any Personal Data submitted through a Career Site will be processed by Teamtailor on our behalf in accordance with applicable contractual and data protection requirements.

Cronofy – limited Personal Data (email address) submitted via our Career Site may be shared with this platform in relation to calendar synchronisation for the purposes of interview scheduling for Candidates.

HiBob – should their application be successful, a Candidate’s Personal Data may be shared onwards to this platform for the purposes of onboarding.

IT Service Providers – IT Service Providers that support our recruitment systems may, where necessary, access our career sites for system maintenance, support and troubleshooting purposes.

Where Third Parties act as Processors on behalf of an Opera Group Company, we will ensure that appropriate contractual arrangements are in place, including data processing agreements requiring them to process personal data only on our documented instructions, maintain appropriate security measures, protect confidentiality, and assist us with our data protection obligations.

Recruitment Agencies & Referees

Where we receive Candidate Personal Data from recruitment agencies, referees, or other third parties, we will process that information only where relevant to the recruitment process and in accordance with applicable Data Protection Legislation.

We will only contact referees where this is appropriate for the relevant stage of the recruitment process.

International Transfers

International transfers may occur where Opera Group Companies or other approved service providers process or access Candidate Personal Data from outside the relevant jurisdiction.

Where we transfer candidate personal data outside the Bailiwick of Guernsey, the United Kingdom, the European Economic Area, or another jurisdiction deemed adequate under applicable Data Protection Legislation, we will ensure that appropriate safeguards are in place before doing so.

These may include an applicable adequacy decision or recognised transfer framework, standard contractual clauses, binding corporate rules, or another lawful transfer mechanism available under applicable Data Protection Legislation.

In limited circumstances, we may rely on an applicable derogation, such as explicit consent, where permitted by law.

Data Retention

Candidate Personal Data will normally be retained for 12 months following completion of the recruitment process, regardless of whether an application is successful or unsuccessful. Earlier deletion may be requested by a Candidate, subject to any legal, regulatory or legitimate business requirements requiring continued retention.

Where reasonably necessary to establish, exercise or defend legal claims, comply with legal or regulatory obligations, respond to complaints, investigations or requests from authorities, relevant Candidate Personal Data may be retained for a longer period.

If a Candidate’s application is successful, the relevant data will form part of their employee record and will be retained in accordance with the relevant Opera Group Company's Data Retention Notice.

Data Security

We have put in place appropriate security measures to prevent Candidates’ personal data from being accidentally lost, altered, disclosed, used or accessed without authorisation. These measures may include access controls, role-based permissions, confidentiality obligations, secure systems, supplier due diligence, and internal policies and procedures designed to protect Candidate Personal Data.

We restrict access to Candidates’ Personal Data to those employees, agents, contractors, consultants and other third parties who have a business need to access the data.

Automated Decision Making

We do not make recruitment decisions based solely on automated processing. We may use recruitment systems to help organise, search, filter, or manage applications, but final recruitment decisions are not made solely by automated means.

If this changes, we will provide candidates with appropriate information about the logic involved, the significance of the processing, and their rights under applicable Data Protection Legislation.

Your Data Protection Rights

You have the right to:

• Be informed regarding who will be processing your data and why

• Request access to your data

• Request correction or deletion of your data

• Withdraw consent to process your data (where applicable)

• Make a data portability request

• Be notified that action has been taken in response to your request

• Object to or restrict processing of your data (including the right to object to direct marketing)

• Not be subject to decisions based on automated processing

• Lodge a complaint with the ODPA (see below)

To exercise your rights, contact People@oak.group

Complaints

If Candidates have complaints about our Processing of their Personal Data, they can raise a complaint with the relevant data protection authority.

The Office of the Data Protection Authority (Guernsey)

Queries & Notice Status

Any questions regarding this Privacy Notice or requests in respect of the Personal Data of Candidates should be directed to People@oak.group

This Opera Group Candidate Privacy Notice sets out our current Notice. It does not form part of any offer of employment or contract and may be updated from time to time.