Privacy Recruitment Policy
PURPOSE
This Recruitment Privacy Policy (‘Policy’) describes how Alberta Group (hereinunder referred to as ‘Alberta’, ‘we’, ‘us’ or ‘our’, ‘the company’) processes the information and personal data related to individuals who enquire about or apply for employment with Alberta (‘you’, ‘your’).
Whether you are a candidate interested in sharing your CV with us or applying for a specific job, or whether you are a referring third party submitting the CV on behalf of a candidate, you should read and understand this document detailing Alberta’s recruitment process and how all candidates’ data is processed by us. For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and the Data Protection Act, (Cap. 586 of the Laws of Malta) (the ‘Data Protection Legislation’), Alberta is the Controller of such personal data as defined in the Data Protection Legislation, and shall process personal data in a fair, lawful and transparent manner in accordance with its legal obligations as contained therein in order to safeguard all rights and protections due to a data subject.
SCOPE
This Policy applies to all job applicants and prospective candidates who interact with our recruitment process whilst enquiring or applying for a post as an employee or subcontractor with Alberta Group.
PURPOSE FOR PROCESSING
As your prospective Employer, we need to collect and process your information, including personal data, to manage your application during the recruitment process and to protect our legitimate interests including in the event of disputes or legal proceedings. Personal data shall be provided by you voluntarily through our Bamboo Hiring Recruitment Platform or through a third-party recruitment agency, acting on your behalf. Please click here [link to ‘PreEmployment Consent Form’] to complete the PreEmployment Consent Form. We will process your personal data according to the General Data Protection Regulation (EU) 2016/679 and the Data Protection Act, Cap. 586 of the Laws of Malta.
CATEGORIES OF PERONAL DATA
By applying for the position, either advertised by us directly or indirectly, you or the third-party agency, acting on your behalf, will be asked to provide information, related to your work experience, education, competencies, and skills. The categories of personal data include, but are not limited to name, surname, date of birth, ID / passport number, address, contact number, email address, nationality; special categories of personal data: country of origin, your photo). You or the third-party agency, on your behalf, may submit the required application information through our Bamboo Hiring Recruitment Platform in the form of a CV, Covering Letter, Employment History, Education History, certificates, references, recommendation letters, etc.
SHOW YOUR INTEREST IN WORKING WITH US
An application for the filling of a vacancy can only be processed once we have received a CV of an interested candidate. CVs can only be accepted when uploaded onto the Alberta Careers online portal following the creation of a profile for the candidate via this portal. No CVs are accepted or received by ordinary mail or email. Should we receive any CVs through such means, such candidates shall be referred to the online Careers portal and their CVs immediately deleted or destroyed. CVs are received either directly by the candidates or via third party referrals such as recruitment agencies or current Alberta employees. If you are a referring third party, it is your responsibility to ensure that you have sought the consent of the candidate you are referring prior to sharing his/her CV with us. We may create a recruitment profile for a candidate on the Alberta Careers portal if specifically, and legitimately requested to do so.
HOW WE ACCESS AND MANAGE CVS
All CVs received are placed on a third party recruitment platform (currently BambooHiring – more info available here) via the Alberta Careers portal and stored, accessed and processed on such portal. BambooHiring is a data processor of that information which Alberta receives via this portal and only processes such personal data upon Alberta’s written instructions and in accordance with their own legal obligations and the contractual obligationsthey have towards Alberta. Once a candidate creates his/her professional profile on the Careers portal, such candidate will receive an automated email confirmation that such profile has been created and Alberta will then have access to the candidate profile and all the information uploaded to or saved in such profile. This information includes all information submitted by the candidate. Access to this information is granted to relevant Alberta employees involved in the respective recruiting panel, on a strict need-to-know basis. Unless specifically requested by the candidate in writing or by any other reliable means, Alberta does not modify, in any manner, any profile once uploaded.
OUR RECRUITMENT PROCESS
All public professional profiles and CVs specifically received and considered suitable, for any given vacancy will be filtered by a human resources officer assigned to that particular recruitment process. Access to those CVs which are deemed acceptable by the human resources officer at this initial stage shall be shared in a secure manner with the interviewing panel and to any other required Alberta personnel on a strict need-to-know basis. Access to such personal data to non-HR personnel shall only remain active and available until the recruitment process for that vacancy has been satisfactorily filled. Shortlisting of candidates is done on the basis of the criteria listed in the job description applied for and following a comparison with other interested candidates. Interviews are conducted on a strictly confidential basis by an internal interviewing panel bound by contractual obligations of confidentiality. The interviewing panel may make use of publicly available social media, public professional profiles and search engine results prior to conducting an interview. Once a candidate is not on the shortlist or selected, the candidate’s CV is deleted from the third party recruitment platform five years after the closing date of the vacancy. This period may be extended if the candidate opts in to keep such CVs and profiles stored indefinitely on the third party recruitment platform via the Alberta Careers portal. The candidate may, however, access, amend and
delete his/her profile at any time at no cost via the Careers portal.
RETENTION PERIOD OF CVS AND PROFILES
Unless recruited – in which case the Employee Privacy Policy shall apply– all candidates shall have their CV kept on the third party recruitment platform for a minimum period of five years in order to contact candidates about any future positions should we believe that their profile is relevant and matches any new roles. However, this period of five years may start running from the date that the candidate (or anyone authorised to do so on his/her behalf) shall have last updated his or her profile. For this reason, you need to know that we too will know when your profile has been accessed or altered by you (or anyone else on your behalf). We consider that it is in our legitimate interest to retain your CV and profile for such period of time as, when you access your profile without deleting it, we understand that you are still interested in working for Alberta, despite not having been our preferred candidate up until then. Given that all positions carry a probationary period of one year, your continued interest would mean that, should the position you were interested in becomes vacant once again during the probationary period of the person employed in that role, you may be invited by us to take on the role should you still be interested in doing so. This amount of time will also allow us to contact you throughout that period in connection with other vacancies of potential interest to you. During this time, only HR personnel will have access to your profile on behalf of Alberta on a strict need-to-know basis. When the five-year period has lapsed from your last date of access, your profile and all its contents will automatically be deleted.
RETENTION PERIOD OF OTHER PERSONAL DATA
Application Information is retained for two years after the end of the recruitment process for unsuccessful candidates. Data related to the background checks is retained for five years after the end of the recruitment process for unsuccessful candidates.
SHARING WITH THIRD PARTIES
Alberta shall treat all CVs, profiles and applications in strict confidence. No CVs or profiles shall be shared at any point in time outside Alberta except, as explained above, with BambooHiring which stores, maps and manages your information.
ACCESS AND USE OF PERSONAL DATA
Throughout the duration that a candidate’s profile exists on the third party recruitment platform, Alberta shall only use that information to contact the candidate via email or telephony in order to inform him/her of any vacancies that he/she may be interested in, in line with his/her profile or as a result of his/her interview. Any personnel within Alberta who would have required access to such CVs or profiles in order to carry out their duties in relation to the recruitment process shall be bound by contractual confidentiality obligations.
COMMUNICATION
Your personal data will also be processed as part of correspondence with you directly, about you with the third parties, acting on your behalf, and as part of the background check. Correspondence includes but not limited to acknowledgement of your application, request for further information, scheduling interviews, outcome of the interview, background check verification, including legal, employment and education.
BACKGROUND CHECK
The background checks are conducted on the final candidates to assess the potential risks related to the: • Prospective candidate’s employment dates, designation, previous employer, reason for termination of employment and eligibility for further employment. • Criminal history, including conviction(s) and probation, the nature of the crime and its relationship to the designation, number of convictions and the time elapsed since the conviction. Credit history for positions involving handling of company cards or bank accounts or having access to critical company assets. Disclosure of Personal Data to Third Parties We will not share your personal data with third parties, unless required otherwise as part of our legal obligations, or to conduct background checks.
YOUR RIGHTS AS A DATA SUBJECT
At any point, while we are in possession of or processing your personal data, you, as the data subject, have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: if Alberta refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the “Complaints” section, below.
COMPLAINTS
If you deem that the processing of your personal data is not being performed in compliance with this policy or with the applicable law, you may lodge a complaint with Alberta’s DPO or with the Competent Authority.
Alberta’s DPO: dpo@alberta.com.mt
Competent Authority: Information and Data Protection Commissioner, Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549 +356 2328 7100 www.idpc.org.mt / idpc.info@idpc.org.mt
FURTHER INFORMATION
Should you wish to ask any questions on how Alberta processes or has processed your personal data or if you would like to make a request to avail yourself of your rights as outlined above, you may do so by contacting Alberta’s Data Protection Officer on dpo@alberta.com.mt. You may also contact the Office of the Information and Data Protection Officer to refer any complaints you may have, on the contact details provided above.