Recruitment Privacy Policy

As part of our recruitment process, COOL’s HR collects and processes personal data relating to job applicants. The personal data may be held by the Company (and its subsidiaries) in paper or in electronic format. The Company (and its subsidiaries) are committed in being transparent about how it collects and uses that data and to meeting its data protection obligations under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. The purpose of this privacy notice is to make you aware of how and why we will collect and use your personal data during the recruitment process. We are required under the GDPR to notify you of the information contained in this privacy notice which applies to all job applicants. If you have any questions about this privacy notice or about how we handle your personal data please contact [email protected]

What personal data is collected?

As part of the recruitment process we may collect the following personal data:

  • Name, address, date of birth and nationality;
  • Contact details and email address;
  • Personal data included in the CV, application form, covering letter or interview notes such as previous work history and experience, education background and photographs;
  • Entitlement to work and reside in Malta, where applicable;
  • Employer references (we will ask your permission first for these);
  • Driving License and TAG Card, where applicable;
  • Recent Police Conduct Certificate (not more than 6 months old).

The Company may also collect, use and process the following special categories of your personal data during the recruitment process:

  • Whether or not you have a disability for which the Company needs to make reasonable adjustments during the recruitment process;
  • Information about criminal convictions and offences;
  • Information not limited to racial or ethnic origin, religious or philosophical beliefs and sexual orientation.

Who is the Data Controller?

Whether received by email, by post or online, the HR Department is the Data Controller for Job Applications. The Data Controller for Job Applications can be contacted on the following email address: [email protected]

Who has access to data?

The personal data received for the purposes of recruitment will be mainly processed by HR. The personal data may be shared internally for the purposes of the recruitment exercise. This includes managers in the department which is offering the vacancy and IT staff if access to the data is necessary for the performance of their roles.

Who we share your personal data with?

We will not share your data with third parties unless your application for employment is successful and we make you an offer of employment. We may then share your data with: Recruitment agencies in relation to the contractual obligations between the Company and them, concerning your application; Any court, tribunal and/or public body to whom disclosure is allowed or required by law or for the pursuing of the Company’s legitimate interest;

How do we process your personal data?

We process your personal data to pursue our legitimate business interests and for administrative purposes including:

  • To evaluate your suitability for the position applied and for potential future vacancies that may arise;
  • Conducting personal checks as permitted by law;
  • Verification of references;
  • To enable us to comply with any legal requirements;
  • To pursue the legitimate interests of COOL and protect our legal position in the event of legal proceedings;
  • Recording of your application for recruiting and hiring purposes.

If in the future we intend to process personal data for a purpose other than that which it was collected, the Company will advise you and request consent.

How do we protect your personal data?

COOL is committed to protect and respect your data. We take the security of your data very seriously. The Company has put in place internal policies and controls to ensure that your data is not lost, accidentally destroyed, misused, or disclosed, and is not accessed except by our employees in the proper performance of their duties. Moreover, any hard copies containing personal data are securely stored.

What are your rights as a Data Subject?

As a data subject, you have a number of statutory rights. Subject to certain conditions, and in certain circumstances, you have the right to: • The right to access your personal data • The right to request rectification of your personal data • The right to withdraw consent • The right to be forgotten (Erasure) • The right to portability • The right to know • The right to object If you would like to exercise any of these rights, please contact us on [email protected].

For how long do we keep your data?

If you are offered a position and have accepted the offer, the personal data provided during the recruitment process will be utilised to initiate the employment relationship and will therefore make part of your employment file.

If your application is unsuccessful, the company will hold your data on file for 6 [six] months from the date on which the Company shall communicate its decision to engage you or not. If you agree to allow us to keep your personal data on file, we will do so for consideration for future employment opportunities for a further period of six (6) months. If, your application has been received through a recruitment agency, we retain your details for a period of one year.

What if you do not provide personal data?

You are under no statutory or contractual obligation to provide data to the Company during the recruitment process. However, if you fail to provide the data when requested, we may not be able to process your application properly, or at all.

This Notice is governed by the laws of Malta. We reserve the right to modify or amend this notice from time to time without giving any prior notice.