PRIVACY NOTICE FOR APPLICATION – MEDIATROOPERS GROUP
Effective Date: 24th February 2025
1. Controller Identity
Technologies and Beyond LTD (“we,” “us,” or “our”) is the Data Controller responsible for your personal data. A Data Controller is the entity that determines the purposes and means of processing personal data.
- Address: Level 4, 69, Carolina Court, Giuseppe Cali Street, Ta’ Xbiex, XBX1425, Malta
- Email for Privacy Queries: [email protected]
2. Purpose of Data Processing
When you submit a spontaneous application (CV, cover letter, etc.), we process your personal data for the purpose of evaluating your suitability for potential future employment with our company.
3. Lawful Basis for Processing
We process your data based on:
- Legitimate Interest (Art. 6(1)(f) GDPR): We process your application based on our legitimate interest in assessing candidates for employment opportunities and managing our recruitment process.
- Consent (Art. 6(1)(a) GDPR): Where we request your consent to retain your personal data beyond the standard retention period, we will rely on your consent. You may withdraw this consent at any time.
- Legal Obligation (Art. 6(1)(c) GDPR): We may retain certain information where necessary to comply with applicable legal or regulatory obligations or to establish, exercise or defend legal claims.
4. Data We Collect
We collect the data you voluntarily provide, including:
- Contact details (Name, email, phone number)
- Professional experience (CV, skills, education)
- Cover letter and any other documents attached.
5. Data Retention Period
- If your application is unsuccessful: If your application is unsuccessful, we may retain your personal data for up to two (2) years based on our legitimate interest in managing our recruitment processes, considering candidates for future suitable roles, and defending potential legal claims.
After this period, we may request your consent to retain your personal data for a longer period for consideration for future employment opportunities. If you provide such consent, we will retain your data for the period specified at the time of consent.
You may withdraw your consent at any time, in which case your data will be deleted unless we are required to retain it for legal reasons.
- If hired: Your personal data will be transferred to your employee file and retained for the duration of your employment. Following the termination of your employment, your data will be kept for an additional retention period of 5 years in accordance with applicable legal and regulatory requirements.
We maintain a data retention policy for personal data in our care. Where your personal data is no longer required, we will ensure it is either securely deleted or made anonymous.
6. Recipients of Your Data
Your personal data is accessed only by our HR team and relevant department managers involved in the recruitment process.
Where you apply for a role based in the Isle of Man, your personal data may be shared with our affiliated entity incorporated in the Isle of Man for the purpose of assessing your application. In such cases, that entity may act as a separate data controller in relation to your application.
We do not sell your data. We may use third-party service providers (e.g., cloud storage providers or recruitment software) that act as data processors and process personal data on our behalf under GDPR-compliant data processing agreements.
7. International Transfers
Where your personal data is shared with our affiliated entity in the Isle of Man, such transfer is permitted on the basis of an adequacy decision issued by the European Commission, which recognises the Isle of Man as providing an adequate level of data protection.
Where personal data is transferred to any country outside the European Economic Area (EEA) that does not benefit from an adequacy decision, we will ensure that appropriate safeguards are implemented, such as the European Commission’s Standard Contractual Clauses.
You may contact us at [email protected] for further information about the safeguards in place.
8. Use of Automated Tools
We may use automated processing tools, including artificial intelligence-based systems, to support the evaluation and categorization of applications. This may involve analysing the information you provide to assess relevance to potential roles.
Recruitment decisions are not based solely on automated processing and always involve meaningful human review.
Where required by law, you may request human intervention, express your point of view, and contest any decision made in relation to your application.
Such processing does not produce legal effects or similarly significant effects without human involvement.
9. Your Rights
In accordance with the General Data Protection Regulation (GDPR), you have the following rights in relation to the personal data we process about you:
- Right of Access
You have the right to request confirmation as to whether we process personal data about you and to obtain a copy of such personal data.
- Right to Rectification
You have the right to request that we correct or update any inaccurate or incomplete personal data we hold about you.
- Right to Erasure (“Right to be Forgotten”)
In certain circumstances, you may request that we delete the personal data we hold about you. Where your data is processed based on your consent, withdrawing that consent may result in the deletion of your data, without affecting the lawfulness of processing carried out prior to withdrawal.
- Right to Restriction of Processing
You have the right to request that we restrict the processing of your personal data in certain circumstances, including where you contest the accuracy of the data or believe the processing is unlawful.
- Right to Object
You have the right to object to the processing of your personal data where we rely on our legitimate interests (or those of a third party) as the legal basis for processing.
- Right to Data Portability
Where processing is based on your consent or the performance of a contract and carried out by automated means, you may request that we provide you with the personal data you have provided to us in a structured, commonly used, and machine-readable format. Where technically feasible, you may also request that we transmit such data directly to another controller.
- Right to Withdraw Consent
Where we rely on your consent to process your personal data, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn.
- Right to Lodge a Complaint
You have the right to lodge a complaint with a supervisory authority for data protection matters. If you are located in Malta, the competent authority is the Information and Data Protection Commissioner.
To exercise these rights, contact us at [email protected]. You also have the right to lodge a complaint with a data protection authority.