For the purpose of the General Data Protection Regulation (“GDPR”) the Data Controller is VCSB Ltd.
We use Recruitee, an online application provided by Recruitee B.V. to assist with our recruitment process. We use Recruitee to process personal information as a data processor on our behalf. Recruitee is only entitled to process your personal data in accordance with our instructions.
Your Personal Information
Information we collect from you
We collect and process some or all of the following types of information from you:
Information we collect from other sources
Recruitee 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.
Recruitee’s technology allows us to search various databases – some publicly available and others not, which may include your personal data (including your CV or Resumé), to find possible candidates to fill our job openings. Where we find you in this way we will obtain your personal data from these sources.
We may receive your personal data from a third party who recommends you as a candidate for a specific job opening or for our business more generally.
Uses Made Of Your Information
Lawful basis for processing
We rely on legitimate interest as the lawful basis on which we collect and use your personal data. Our legitimate interest is the recruitment of staff for our business.
Purposes of processing
We use information held about you in the following ways:
Automated decision making/profiling
We may use Recruitee’s technology to select appropriate candidates for us to consider based on criteria expressly identified by us, or typical in relation to the role for which you have applied. The process of finding suitable candidates may be automatic, however, any decision as to who we will engage to fill the job opening will be made by our staff
Disclosure Of Your Information
As set out above, we may pass your information to our third party service providers, including Recruitee, who use it only in accordance with our instructions and as otherwise required by law.
How We Store Your Personal Data
We take appropriate measures to ensure that all personal data is kept secure including security measures to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore any transmission remains at your own risk.
Where we store your personal data
The data that we collect from you and process using Recruitee’s services may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing and processing.
In particular, your data may be accessible to our service providers‘ staff in the USA as well as other locations worldwide and may be stored on servers in the USA as well as in the EU. The USA do not have the same data protection laws as Malta and the EEA.
A Data Processing Agreement has been signed between VCSB Ltd and each of its data processors. These data processor agreements are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal data.
How long we keep your personal data
We will hold all the data received for recruitment purposes for a maximum of one year. Prior to that your personal information will be deleted without undue delay on receipt of a written request by you (or another person engaged by you) to us.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
For further information on each of those rights, including the circumstances in which they apply, see the guidance from the Office of the Information and Data Protection Commissioner Malta on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
How to Complain
We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in Malta is the Information Commissioner who may be contacted at https://idpc.org.mt/en/Pages/contact/complaints.aspx.