This notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) is a new regulation that replaces the Data Protection Regulation (Directive 95/46/EC) The Regulation aims to harmonise data protection legislation across EU member states, enhancing privacy rights for individuals and providing a strict framework within which commercial organisations can legally operate.
Your new rights under the GDPR are set out in this notice and were last updated May 2022.
The Information we collect
To carry out our core recruitment and talent advisory activities, we collect information about you which may include: your name, address and post code; private and corporate e-mail address and phone number; financial information and compliance documentation; references verifying your qualifications and experience and your right to work in Malta; curriculum vitae and photograph; employment details and preferences; links to your professional profiles available in the public domain e.g. LinkedIn, Twitter, Facebook for Business or corporate website.
How we collect this information
The information we collect about you will be provided by you, either by you applying to jobs online or emailing us directly or by corresponding with us by phone, e-mail or otherwise. It will also include information you provide when you register to use our website, subscribe to our services, attend our events, participate in discussion boards or other social media functions on our website, enter a competition, promotion or survey, and when you report a problem with our site.
We may also obtain information about you from other sources such as LinkedIn, corporate websites, job board websites, online CV libraries, your business card, personal recommendations, and any relevant social media sites. In this case – and within 30 days of collecting – we will inform you that we hold this personal data, the source the data originated from, whether it came from publicly accessible sources, and for what purpose we intend to retain and process your personal data.
Our legal basis for processing data:
The information you provide to us is used by us to:
(a) provide our recruitment and talent advisory services to you, whether you are a client, candidate or a user of our website and or / services;
(b) enable you to submit your CV generally, to apply for specific jobs or to be informed of new opportunities;
(c) provide information on suitable job opportunities to people who register with us, to match your profile with suitable job vacancies and to assist us in finding a position that is most suitable for you including the evaluation of your data against vacancies which we may have that we determine may be suitable for you;
(d) to provide you with recruitment and talent advisory advice and insights
(e) answer your enquiry;
(f) provide other services related to or supplementary to the above; services directly to you to your professional, personal or business email address; and
(g) where we have a bona fide requirement by law to process it, including by disclosing the data to third parties, for example, to comply with any applicable law, regulations, legislation, licensing requirements, compliance requirements, detection of crime, the collection of taxes or duties, and /or in order to comply with our legal obligations and/ or to comply with any applicable law, regulations and court order
This list is not exhaustive and we may seek to process, use or disclose your information for any other purpose which has not been listed above always with your explicit consent. The more information we have about you the more bespoke we can make our service.
Where appropriate, we will seek your consent to undertake some of these activities.
We may also use the information you send to us via the websites and/or services, to communicate with you via email and, possibly, other means, or to send you our newsletter, if this is in accordance with your marketing preferences. However, you will always be able to opt out of such communications at any time.
Automated Decision-Making and Profiling
Your Personal Data will not be used for any automated decision-making or profiling which produces legal effects concerning you or similarly significantly affects you.
How do we share your personal data?
We do not share your personal information to anyone except as set out herein. Primarily we will share your information with prospective employers ( our clients ) to increase your chances of securing a job. All job applications/enquiries /discussions are confidential and we will always ask for your express, written permission first, before sending your details to any prospective employer ( our clients).
Within the scope of the purposes outlined above, we may outsource collected personal information to outside contractors/service providers to carry out our services and comply with any necessary legal and regulatory obligations and / or otherwise to carry our service. If we do so, we will take contractual measures to ensure that they process your data in a manner consistent with this Policy.
Prospective Employers are independent third parties, Data Controllers, and are legally obliged to protect your data in line with regulations and GDPR and in the highest confidentiality.
In the event of a sale, merger, receivership or transfer of all assets of our company, we reserve the right to assign or share your personal information with such third parties and their advisers, you will be sent notice of such an event should it occur with the ability to opt-out of such a transfer.
Where we store your personal data
All information stored on our recruitment software is secured through the Microsoft Azure Infrastructure and located at two data centres locations within Europe. Our primary centre is located in Microsoft’s Western European centre, and these facilities are secured by a series of measures, including (but not limited to) biometric access, security alarm systems and round-the-clock security staff. Additional security information on Microsoft’s data centres can be found here.
How long we keep your data for
We retain different types of data for differing periods of time. The criteria we use to determine whether we should retain your personal data and how long for include:
- The nature of the personal data
- Its perceived accuracy of your data
- Your engagement levels with our services
- Our legal obligations following an offer or when a placement has been made.
We may archive part or all of your personal data, or retain it on our financial systems but delete all or part of it from our recruitment software system. On removal, we may anonymise parts of your data – particularly following a request for suppression or deletion of your data – to ensure we do not re-enter your personal data to our database, unless you have requested us to do so.
Our current retention period for data on candidates who have not been placed or are no longer showing any signs of engagement with our services, is 24 months.
The processing of your Personal Data is not carried out in order to fulfil a statutory requirement. The processing of your personal data by us is required in order for us to carry out our services.
The GDPR provides you with the following rights:
- The right to be informed about the personal data we process on you
- The right of access to the personal data we process on you
- The right to rectification of your personal data
- The right to erasure of your personal data in certain circumstances
- The right to restrict processing of your personal data
- The right to data portability in certain circumstances
- The right to object to the processing of your personal data
- The right to be informed of the source from where your personal data originated
- The right to withdraw your consent
- The right not to be subjected to automated decision-making and profiling
Please note that your rights in relation to your personal data are not absolute and we may not be able to entertain such a request if we are prevented from doing so in term of an applicable law.
Right to lodge a complaint with a supervisory authority:
If you have any complaints regarding our processing of your personal data, we kindly ask that you please attempt to resolve any issues you may have with us first by contacting us at the contact details included above. However, please note that you always have a right to lodge a complaint with the Office of the Information and Data Protection Commissioner in Malta (www.idpc.gov.mt).
The above list is not an exhaustive list of your rights, further information can be found at https://ec.europa.eu/info/law/law-topic/data-protection_en
Changes to our privacy notice
While we take all due care in ensuring the privacy and integrity of the information that you provide to us, we recognise that no data transmission over the internet can be 100% guaranteed as secure. The possibility exists that this information could be unlawfully observed by a third party while in transit over the internet. We accept no liability should this occur.