Recruitment Privacy Policy
GasanMamo Insurance Ltd (GMI), having company registration number C3143 and its registered office at Head Office, Msida Road, Gzira, Malta, is the data controller as defined by the relevant data protection laws and regulations, in particular the General Data Protection Regulation (EU 2016/679).
This recruitment privacy policy provides information on the personal data that we collect about you, how we process such data, with whom we will share it throughout the recruitment process, the retention period, and your rights in respect to your personal data.
The information that we collect
As part of the recruitment process, certain personal information about you is required to be processed by us. We process such personal data only as necessary for the purposes of your job application with us or as required by law or regulatory requirements. Your job application will be sent securely to GMI’s Human Resources department, and access to your personal information is only granted to GMI’s human resources department and the
relevant departmental management, on a strict need-to-know basis. The personal data that we process for recruitment purposes may include:
- Your name, address, date and place of birth, and nationality.
- Your contact details such as residential address, email address, mobile, and landline telephone numbers. Data concerning your identity such as photo ID, driving license, passport information, identification number, and national insurance number.
- Your employment history.
- Criminal history checks such as the Police conduct certificate.
- Your previous salary packages and benefits.
- Your education level, including professional qualifications and skills.
- Your previous employer’s feedback.
- Work permit information.
- Interview assessment results.
During the recruitment process, we may also collect personal sensitive data about you, such as health data, including medical conditions. This data is collected so we can make the required arrangements to comply with regulatory obligations such as Health and Safety regulations.
Expressing Your Interest in a Career at GasanMamo
To process an application for a vacancy at GasanMamo, we require the submission of a CV or public professional profile from the interested candidate. These documents must be uploaded through the GasanMamo Careers online portal after the candidate has created a profile on the platform. Any CVs received through these channels will be directed to the GasanMamo Careers portal, and the original submissions will be promptly deleted or destroyed.
CVs and public professional profiles may be submitted directly by candidates or through third-party referrals, such as recruitment agencies or current GasanMamo employees. If you are submitting on behalf of a candidate, it is your responsibility to ensure that the candidate has provided their consent before sharing their CV or public professional profile with GasanMamo. In certain cases, GasanMamo may create a recruitment profile for a candidate on the GasanMamo Careers portal upon specific and legitimate request.
How GasanMamo Accesses and Manages CVs and Public Professional Profiles
All CVs or public professional profiles received are uploaded to a third-party recruitment platform (currently Talexio—more information available at www.talexio.com) via the GasanMamo Careers portal, where they are stored, accessed, and processed. Talexio acts as a data processor for this information, handling it exclusively according to GasanMamo’s written instructions and in compliance with its own legal and contractual obligations towards GasanMamo.
After a candidate’s public professional profile is created, they will receive an automated email confirmation of the profile creation. GasanMamo then gains access to all candidate profiles and any information uploaded or saved within them, such as CVs and the candidate’s notes or comments. This information is accessible only to relevant GasanMamo staƯ on a strict need-to-know basis.
CVs are shared internally only when necessary for the recruitment process to fill a current or potential vacancy. Such sharing is conducted using industry-standard methods to ensure that your personal data is protected against external interference at all times. For further details, please refer to the section titled “How We Conduct the Recruitment Process” below.
GasanMamo does not alter any profile once it has been uploaded unless specifically requested by the candidate in writing or through another reliable method.
How to Access and Manage Your Public Professional Profile
Once created, the candidate shall have access to all the information which he/she has included and uploaded into his/her public professional profile and can update it accordingly. The candidate will receive an automated email notification that such a profile has been modified together with instructions to follow should the candidate disagree with such modification or wish to delete or modify his/her profile once more.
In every email automatically sent by the 3rd party recruitment platform, profile-owners will always be reminded of their right to access, object to, suspend, rectify and erase any personal data contained in their profile.
With respect to your right to erase your personal data, please refer to the section on Request the erasure of your personal data for more details.
Retention of CVs and Public Profiles
Unless recruited – in which case the Employee Privacy Policy shall apply – all candidates shall have their CV kept on the 3rd party recruitment platform for a period of six months in order to contact candidates about any future positions should we believe that their profile is relevant and matches any new roles. However, this retention period may start running from the date that the candidate (or anyone authorized 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 GasanMamo, despite not having been our preferred candidate up until then. Given that most positions carry a probationary period of six months, your continued interest would mean that, should the position you were
interested in becoming vacant once again during the probationary period, 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 as you continue to progress in your career elsewhere. During this time, only HR personnel will have access to your profile on behalf of
GasanMamo on a strict need-to-know basis. When the retention period has lapsed from your last date of access, your profile and all its contents will automatically be deleted. Should you object to the processing or retention of your data as an unsuccessful candidate, you can at any time request that your CV and personal details be deleted from our database in accordance with the section ‘Object to the processing of your data’below.
How We Conduct the Recruitment Process
All public professional profiles and CVs specifically received and considered suitable for any given vacancy will be filtered by a human resources oƯicer assigned to that particular recruitment process. Access to those CVs which are deemed acceptable by the human resources oƯicer at this initial stage shall be shared in a secure manner with the interviewing panel and to any other required GasanMamo personnel on a need-to-know basis. Unless, there is a specific request for deletion of your CV, during the retention period these CVs may also be shared with other departments in GasanMamo in respect of other relevant vacancies which may arise and which could be of potential interest to the candidate. 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. Should the candidate not be selected for the position for which he has applied, the human resources oƯicer may share the CV with senior personnel within GasanMamo if there is the possibility of another suitable vacancy for the andidate within the company. 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.
The interviewing panel may make use of publicly available social media, public professional profiles, and search engine results. Once a candidate is not on the shortlist or selected for the role for which he has applied, the candidate’s CV is deleted from the 3rd party recruitment platform 6 months 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 3rd party recruitment platform via the GasanMamo Careers portal. The candidate may, however, access, amend and delete his/her profile at any time at no cost via the GasanMamo Careers portal. Each candidate shall be reminded of the contents of this paragraph in any communication from GasanMamo informing such a candidate that his/her application has not been successful.
Whether or not a candidate decides to opt-in for the retention of his or her profile is entirely his/her choice and shall have no eƯect on whether or not such candidate is recruited.
Sharing with 3rd Parties
GasanMamo shall treat all CVs, profiles, and applications in strict confidence. No CVs or profiles shall be shared at any point in time outside GasanMamo except, as explained above, with Talexio solely for the purpose of storing, mapping, and managing your information.
Your rights as a data subject Under the General Data Protection Regulation (EU 2016/679) you have various rights in respect to your personal data, particularly you have the right to request:
- Access to the personal data we hold about you.
- Update to your personal data we hold about you or correct such personal data that you think is incorrect or incomplete.
- Restriction to the processing of your personal data.
- Deletion of your personal data
Your rights as a data subject
Under the General Data Protection Regulation (EU 2016/679) you have various rights in respect to
your personal data, particularly you have the right to request:
- Access to the personal data we hold about you.
- Update to your personal data we hold about you or correct such personal data that you think is incorrect or incomplete.
- Restriction to the processing of your personal data.
- Deletion of your personal data
Asking to delete your personal data during the recruitment process would mean that we will be unable to proceed with the processing of your job application with GasanMamoInsurance Ltd.
By email: [email protected]
By post:
The Data Protection Officer
GasanMamo Insurance Ltd.
Head Office
Msida Road
Gzira
Asking to delete your personal data during the recruitment process would mean that we will be unable to proceed with the processing of your job application with GasanMamo Insurance Ltd.
Changes to this Recruitment Privacy Policy
We may amend this Recruitment Privacy Policy from time to time without giving any prior notice. You should regularly check this policy for any updates.