Last updated June 2018
This notice complies with the EU General Data Protection Regulation ((EU) 2016/679) (GDPR). It serves as a notice for individuals applying for jobs or assignments with us. It notifies prospective employees, workers and contractors about the personal data that we hold relating to them, how they can expect their personal data to be used and for what purposes.
WHAT IS THE PURPOSE OF THIS DOCUMENT?
Comlux Malta Ltd, (the Company, our, we us) is a “data controller”. This means that we are responsible for deciding how the Company holds and uses personal information about you. You are being sent/given a copy of this privacy notice because you are applying for work with us (whether as an employee, worker or contractor). It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).
It is pertinent to note that if you are successful in the recruitment process this privacy notice ceases to apply and that you will be then expected to read and understand our privacy notice for employees, workers and contractors.
DATA PROTECTION PRINCIPLES
The Company will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:
- The information you have provided to us in your curriculum vitae and covering letter whether online or in hard copy.
- The information you have provided on our application form, be it online or physical, including name, title, address, telephone number, personal email address, date of birth, gender, employment history, qualifications, medical certificate, copy of licence and passport.
- Any other information you provide to us during an interview but not limited to references and copies of relevant certificates.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about candidates from the following sources:
- You, the candidate.
- In case your CV has been provided by a recruitment agency, we collect the following categories of data: CV, License, Valid Medical, updated Log Book and any other relevant documentation, if applicable, pertaining to the vacancy you have applied for.
- Your named referees, from whom we collect the following categories of data: Information about personality attributes and technical competency in past work environments.
- The following data from third parties is from a publicly accessible source, including but not limited to Facebook, Linked-In and Job Boards such as Keep Me Posted and Aviation Search.
HOW WE WILL USE INFORMATION ABOUT YOU
We will use the personal information we collect about you to:
- Assess your skills, qualifications, and suitability for the role.
- Carry out background and reference checks, where applicable.
- Communicate with you about the recruitment process.
- Keep records related to our recruitment processes.
- Comply with legal or regulatory requirements.
It is in our legitimate interests to decide whether to appoint you to the role since it would be beneficial to our business to appoint someone to that work.
We also need to process your personal information to decide whether to enter into a contract of Employment OR Service with you.
Once we receive, your CV and your application form or you have been referred by a recruitment agency, we will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, we will decide whether your application is strong enough to invite you for an interview. If we decide to call you for an interview, we will use the information you provide to us at the interview to decide whether to offer you the role. If we decide to offer you the role, we will then [take up references before confirming your appointment.
If you fail to provide personal information
If you fail to provide information when requested, which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully. For example, if we require a references for this role and you fail to provide us with relevant details, we will not be able to take your application further.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
We will use your particularly sensitive personal information in the following ways:
- We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We do not envisage that we will process information about criminal convictions during the recruitment stage.
If we would like to offer you the role we might ask you to show us a recent police conduct certificate before signing the contract. In that case we will hand the certificate back once seen. We might also offer you the role conditional on checks and any other conditions, such as references, being satisfactory. Depending on the nature of the role, we might be required to carry out a background check to satisfy ourselves that there is nothing in your history which makes you unsuitable for the role.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.
Why might you share my personal information with third parties?
We will only share your personal information with the following third parties for the purposes of processing your application: Customers or Aircraft Representatives of the operation in which recruitment is taking place. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
We will retain your personal information for a period of  months after we have communicated to you our decision about whether to appoint you to the role. We retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.
If we wish to retain your personal information on file, on the basis that a further opportunity may arise in future and we may wish to consider you for that, we will write to you separately, seeking your explicit consent to retain your personal information for a fixed period on that basis.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Christine Fava on firstname.lastname@example.org] in writing.
RIGHT TO WITHDRAW CONSENT
When you applied for this role, you provided consent to us processing your personal information for the purposes of the recruitment exercise. You have the right to withdraw your consent for processing for that purpose at any time. To withdraw your consent, please contact Christine Fava, HR Manager Fly Comlux on email@example.com and Jean-Paul Xuereb, Head of Human Resources Fly Comlux on firstname.lastname@example.org . Once we have received notification that you have withdrawn your consent, we will no longer process your application. We will dispose of your personal data securely unless there are other legal obligation.