Privacy Policy Statement

Igp Operations Limited is fully committed to protecting personal data and will act as a data controller in all recruitment-related personal data processing done via this machibets.com website. that might include from time to time other members of our corporate group or clients that have entrusted us with finding the right match for their team.

This Privacy Policy Statement (“Privacy Policy”) describes the ways we collect information from and about you, what we do with the information, what your privacy rights are and how you can get more information. By applying for one or more of our positions you agree to the Privacy Policy and the way your data is being processed.

Purpose

The Privacy Policy describes the handling of the personal data of any prospective candidates or leads, such as those individuals who expressed an interest in receiving news and details about future employment or collaboration opportunities or other related communications. For any queries or more information in relation to this Privacy Notice please contact the DPO at [email protected].

From time to time, in order to streamline the recruitment process and to make sure most time is spent where it truly matters – matching the perfect candidates with the perfect positions, we might use a third-party online application system to assist with Our recruitment process (hereinafter “Applicant Tracking System” or “ATS”). We use Bamboo to process personal data as a data processor on our behalf. The ATS is only entitled to process your personal data in accordance with Our instructions and subject to a contract that is in place between us and the third-party provider.

Definitions

Data: any information relating to an identified or identifiable natural person (‘data subject’)
Data Subject: means the individual to whom the personal information relates;
Law:
– Regulation EU (2016/679) of the European Parliament and of the council of 27 April 2016 on the protection of natural persons with regard to the processing of the personal data and on free movement of such data, and directive 95/46/EC (General Data Protection Regulation)
– The Maltese Data Protection Act (DPA – Chapter 586 of the Laws of Malta) as well as any other law related to data protection that might or will be published in relation to the DPA

Data Controller: the party that determines the purposes for which and the means by which personal data is processed;
Policy: Means this General Data Protection Policy;
Processing: Means obtaining, recording or holding the information or Data or carrying out any operation or set of operations on the information of Data, including:

• Organization, adaption or alteration of the information of Data;
• Retrieval, consultation, or use of the information or Data;
• Disclosure of the information or Data by transmission, dissemination or otherwise making available;

• Alignment, combination, blocking, erasure
• Destruction of the information or Data

Special categories of personal Data: (known as “sensitive personal data”) means personal information about an individual’s race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (or non-membership), genetics information, biometric information (where used to identify an individual) and information concerning an individual’s health, sex life or sexual orientation.

Data processing

What data do we process?

a) We collect and process some or all the following types of information from you:
• Information that you provide when you apply for a role. This includes information provided through an online job site, via email, in person at interviews and/or by any other method. In particular, We process personal details such as name, email address, address, date of birth, qualifications, experience, information relating to your employment history, skills and experience that you provide to Us.

• If you contact Us, we may keep a record of that correspondence.
• Details of your visits to the online third-party ATS tool including, but not limited to, traffic data, location data, weblogs and other communication data, the site that referred you to the ATS and the resources that you access.

b) We collect and process some or all the following types of information from other sources

• The ATS provides Us with the facility to link the data you provide to Us, with other publicly available information about you that you have published on the Internet – this may include sources such as LinkedIn and other social media profiles.

We will never collect or process any very sensitive data related to you. If a specific job requires this kind of information due to the sensitive nature of the position, all very sensitive data will be only processed based on your consent and will be stored and processed with proper extra security measures in place.

The type of information that we need to process for your legitimate interest, in order to evaluate the best job fit for you, might differ based on the seniority, geolocation and profile of the job. However, the main categories on data are going to be:

• Contact information: name, phone number and email address.
• Personal information such as date of birth, geographical location.
• Employment history, education, qualifications and skill set
• Visas, passport details, bank details and tax and national insurance details
• Information relating to job preferences and personal hobbies

How are we processing the data?

Your data will only be processed based on your consent, performance of a contract and/or legitimate interest.

Please note that when it comes to keeping your data on file if you are not undergoing a current recruitment process as well as keeping you up to date to our current openings and opportunities we will process your data based on consent alone. You are not obliged to give your consent and refusing to give your consent will not lead to any detriment to you. You have the right to withdraw your consent at any time by contacting our DPO or clicking the ‘unsubscribe’ link in any marketing materials sent to you.

Purposes of processing

Your data will be used for legitimate interest only, as following:

• To consider your application in respect of a role for which you have applied.
• To consider your application in respect of other roles we may have available at the time.
• To communicate with you in respect of the recruitment process.
• To find appropriate candidates to fill Our job openings.
• To test, on a case-to-case basis, the best candidate for the position, by using skill tests
• To check on a case-to-case basis, the best fit for the already existing team, by using personality tests
• To check on a case-to-case basis previous employment references and criminal records.

How We Store Your Personal Data

Security

We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal data to personnel on a need-to-know basis. Personnel accessing your information will do so only as authorised and subject to the duty of confidentiality.

Where we store your personal data

For service providers based outside the European Economic Area (“EEA”), whenever We transfer your personal data outside of the EEA, We do so ensuring a similar degree of protection to your personal data as provided by Us to you. To ensure the protection of your personal data, We will implement one of the following safeguards:

• Adequacy Basis – We will ensure that the transfer of your personal data is undertaken with entities established in countries that are deemed to provide an adequate level of protection for personal data by the European Commission.
• Standard Contractual Clauses – In absence of an adequacy decision basis, We may use the Standard Contractual Clauses approved by the European Commission, providing the same standard of protection to personal data as in the EEA.

How long we keep your personal data

We will hold your personal data for a maximum of one year from the end of the last communication unless the data needs to be retained for a further period in view of any claim or complaint made during the said retention period.

Requests for deletion of personal data may be submitted to us at any time by contacting the DPO at: [email protected]. Upon receipt, CV and any documents submitted will be deleted. In certain cases, this right can be outweighed by other regulations we are legally obligated to fulfil, but in this case you will be notified accordingly (see right to be forgotten).

Your rights

We are committed to respecting your rights under Privacy regulations and will be here to support you in requesting them. In summary, those include:

1. You have the right to access your personal data – You can always contact us and submit a Subject Access Request and we will provide you with a list with all the information that we have and process about you in a structured, commonly used and machine-readable format as soon as possible but not later than 30 days from the moment of the request;
   Please note: If a request is done and our Data Protection Officer has any reasonable doubt that the request to provide personal data that we have collected on that particular user might not be done by the Data Subject, or to exercise any other rights outlined in this policy, we will ask the user to verify themselves to prevent disclosure of personal data to the wrong person.
2. You have the right to rectification – you can always contact us and require Us to correct any mistakes or complete/update any information that relates to you which we hold;
3. ou have the right to be forgotten – please note that this is not an absolute right, however, we will erase your data in all the cases where we do not have other legal obligations to retain it; Igp Operations Limited is committed to finding the best individuals to balance and empower a team. With that in mind, please note that there might be a few cases when in order to protect our already existing employees, minimum information needed to identify a candidate will be kept in documented cases of gross misconduct. These potential candidates will be removed from our future projects.
4. You have the right to object at any time to processing of personal data concerning you for direct marketing. Keep in mind all marketing processing is done based on consent, and you are not obliged to give your consent. Refusing to give your consent will not lead to any detriment to you. You have the right to withdraw your consent at any time by contacting our Data Protection Officer or clicking the ‘unsubscribe’ link in any marketing materials sent to you.
5. You have the right to object to decisions being taken by automated means – however please keep in mind that we do not use such tools.
6. You have the right to be informed at all times as to what data we have in regards to you and how it is processed; We take this right seriously by providing you with this detailed privacy policy, by having a very streamlined SAR procedure and by having a cookie inventory tool on the website that offers full visibility and freedom to opt in or out each individual cookie or type of cookies.

If you would like to exercise any of those rights, or if you have any extra questions in regard to your rights please Contact Us.

Please note: If a request is done and our Data Protection Officer has any reasonable doubt that the request to provide personal data that we have collected on that particular user might not be done by the Data Subject, or to exercise any other rights outlined in this policy, we will ask the user to verify themselves to prevent disclosure of personal data to the wrong person.

Right to lodge a complaint

We hope that we can resolve any query or concern you raise about Our use of your information, so we are strongly advising you to contact our Data Protection Officer in case of any concerns.

If however you would rather lodge a complaint, you have the right to do so with the local data protection authority in your country of residence or with the Information and Data Protection Commissioner (//idpc.org.mt).

Contact

All questions, comments and requests regarding this Privacy Notice should be addressed to the Data Protection Officer at [email protected] or at the Our registered address undertaking the recruitment process