GROUP RECRUITMENT DATA PRIVACY POLICY 

Policy to regulate what General Personal Data is required to be collected by the Human Resources Department 

Effective date: 25 May 2018 

Introduction 

This Notice applies to all data subjects (applicants) applying for an employment vacancy at V.J. Salomone Limited, a limited liability company, registered in Malta (C-712), with its registered office located at Upper Cross Road, Marsa, Malta, and the following group undertakings also registered in Malta as limited liability companies: 

 

This Notice provides how V.J. Salomone Limited and its group undertakings, (hereinafter “the Group”, “V.J. Group”, “us” or “we”), use the personal information relating to applicants ("you" or "your"). 

This Notice is intended to help you understand why and how we may use your information. 

Policy Scope 

For the purposes of the General Data Protection Regulation (EU 2016/679) (GDPR) in the European Union, the Human Resources Department of VJ Salomone Limited and all of its subsidiary companies will be a data controller of Personal Data relating to applicants. 

The Type of Personal Information We May Hold About You 

During the recruitment process we may collect various categories of Personal Data depending on the nature of the vacancy. "Personal information" means information about you, and from which you could be identified, including information which may be protected under applicable privacy or data protection laws. 

The Personal Data we may collect is limited to information necessary to enable us to select a suitable candidate for a vacant position within the Group and may include the following categories of Personal Data: z:\hr sop\hr_sop_g001 group recruitment data privacy policy.docx Page 2 of 5 HR-SOP G001 

Type of Personal Information 

Examples 

Please note that the examples are illustrative and non-exhaustive 

Information about you: 

Name, surname, address, date of birth, marital status, nationality, gender, preferred language and details of any disabilities. 

Information to contact you: 

Name, surname, address, telephone and email address. 

Information to identify you: 

Photographs, identity card/passport number and/or driving license details (if required for a particular role). 

Information about your suitability to work for us: 

References, interview notes, work visas (if applicable), ID/passport details and/or driving license information, records/results of pre-employment checks, including criminal record checks (police conduct). 

Information about your skills and experience: 

CVs, resumes and/or application forms, references, records (certificates) of qualifications, skills, training and other compliance requirements. 

Information about your terms of employment with us: 

Letters of offer and acceptance of employment, your employment contract, billing and subscription information. 

More categories of Personal Data may be requested for successful candidates in order for us to be able to enter into an employment contract with you, and also to fulfil our legal obligations as an employer. The Personal Data collected from employees is governed by a separate Privacy Policy, which will be communicated to the successful applicants, upon requesting such additional categories of Personal Data.

 

What Your Personal Information is Used For

We will process your personal information where such processing is: (i) reasonably necessary for compliance with a legal obligation to which V.J. Salomone Limited or any of its group undertakings is subject (for example, within the field of employment); or (ii) is within V.J. Group's legitimate business interests as your potential employer.

V.J. Group uses your personal information for the purpose of selecting the best suited applicant for vacant positions that may arise. More specifically, we may process your personal data:

In this regard, your Personal Data is being processed in our legitimate interest to select the best suited candidate for vacancies which may arise.   

 

Sharing and Disclosure of Your Personal Information

We are committed to maintain the confidentiality of information relating to you. We will also comply with all legal requirements regarding the sharing and disclosure of personal information. We may disclose information to the following recipients where it is legitimate to do so:

 

Security and Integrity of Personal Information

We maintain appropriate administrative, technical and organisational measures designed to help safeguard the confidentiality and integrity of data collected to protect it against accidental or unlawful destruction, accidental loss, unauthorized alteration, disclosure or access, misuse, and any other unlawful form of processing of the personal information in its possession. In adherence with data protection laws and internal policies, V.J. Group addresses security at all appropriate technology infrastructure points Such security measures include but are not limited to password protection, encryption, firewalls, physical locks, and training on data security and data protection methods. These safeguards are designed to restrict access to Personal Data by unknown and unauthorised individuals. V.J. Group trains employees regarding its data privacy policies and procedures and permits authorised employees to access candidate’s personal information on a need to know basis, as required for their role. All Personal Data pertaining to applicants is stored locally within the Organisational infrastructure. 

 

How Long We Keep Your Information

We will hold your information in line with our data retention policies and applicable law. We will retain your personal information for only as long as appropriate to fulfil the purposes for which we collected that personal information, unless the law permits or requires that we retain it for longer.

 

Data subject rights

Subject to applicable local law, you may have the right to:

For more information about your rights and how to exercise them, please contact our Data Protection Officer via email: dpo@vjsalomone.com We will make every effort to respond to any request from an individual, within one calendar month, from receipt of the request.

Contact us

If you have any questions or complaints about this Notice or how we use your personal information, please speak to the Group’s Data Protection Officer (dpo@vjsalomone.com). You also have the right to complain to the local supervisory authority, the Office of the Information and Data Protection Commissioner (IDPC). The contact details of the supervisory authority are as follows:

 

Supervisory authority contact details 

Contact Name: 

The Commissioner 

Office of the Information and Data Protection Commissioner 

Address line 1: 

Level 2, Airways House 

 

Address line 2: 

High Street 

Address line 3: 

Sliema 

Email: 

idpc.info@idpc.org.mt 

Website link: 

https://idpc.gov.mt 

Telephone: 

2328 7100 

 

Updates to this Policy Notice 

This Policy Notice may be updated periodically and without prior notice to reflect changes in the Group's HR privacy practices. We will let you know about any significant changes to this Notice and will indicate at the top of the Notice when it was most recently updated.