Job Applicants Privacy Policy

By submitting your job application, you acknowledge that you have read, understood, and agree to the terms and conditions of this Job Applicants Privacy Policy.

 

Introduction

At NetRefer, we are committed to protecting the personal information of our job applicants. This Privacy Policy covers the personal information of job applicants during the application or recruitment process, including but not limited to when you respond to a job opening on netrefer.com/careers, or when you are referred for a job opening at NetRefer. If you are offered and accept employment with NetRefer, the information collected during the application and recruitment process will become part of your employment record.

This privacy statement supplements our existing Privacy Policy, which gives you specific information on how we process personal data.

What Personal Information do we Collect?

Types of Information: We may collect various types of personal information from job applicants, including but not limited to:

  • Contact information (e.g. name, address, email address, phone number);
  • Resume/CV, cover letter, and other application documents;
  • Photographs you may submit with your application;
  • Employment history, educational background, and qualifications;
  • References, recommendations;
  • Records we create during interviews or correspondence with you;
  • Skills and certifications;
  • Information about your current and desired salary, including benefits information;
  • Any other information provided by you in writing or verbally during the process;
  • Any other information provided by you in writing or verbally during the process;

Sources of Information: We may collect personal information from the following sources:

  • Directly from the job applicant, such as through application forms, emails, or interviews;
  • Recruitment agencies or background check providers;
  • Publicly available sources (e.g. professional networking platforms);
  • Third parties, such as references supplied by former employers.

Special Categories: We may also collect the following categories of your personal information during the recruitment process:

  • Whether or not you have a disability for which we need to make reasonable adjustments during the recruitment process;
  • Information about criminal convictions and offences.

Use of Personal Information

Purpose: We may use your personal information for the following purposes:

  • Evaluating and assessing job applicants' suitability for employment;
  • Verifying qualifications, employment history, and references and conducting background checks;
  • Communicating with applicants throughout the recruitment process including, where applicable, informing you of other potential career opportunities at NetRefer;
  • Complying with legal and regulatory requirements;
  • Where requested by you, assisting you with obtaining an immigration visa or work permit where required;
  • Making improvements to NetRefer’s application and/or recruitment process including improving diversity in recruitment practices;
  • Proactively conducting research about your educational and professional background and skills and contacting you if we think you would be suitable for a role with us.

Consent: By submitting your job application (either directly or indirectly), you consent to our use of your personal information as outlined in this Privacy Policy.

Sharing of Personal Information

Internal Disclosure: Within NetRefer, your information can be shared with select employees, such as members of the HR and recruitment team, interviewers involved in the recruitment process, managers in the business area with a vacancy and IT staff if access to the data is necessary for the performance of their roles.  Your personal information will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including email).

Third-Party Service Providers: We may share your personal information with third-party service providers who are working on our behalf and require access to your information to carry out that work. Examples include recruiters, cloud hosting providers, and service providers who assist us in conducting background checks or other pre-employment screenings.

Where we need to transfer or store your personal data outside the European Economic Area (the “EEA”), we will only do so using Standard Contractual Clauses approved by the European Commission, which contractually oblige third party organisations in those countries to comply with the same data protection standards as legislated within the EEA.

Legal Obligations: We may disclose personal information if required to do so by law or in response to a legitimate request from a regulatory or law enforcement authority.

Legal Grounds for Processing

Legitimate interest: NetRefer has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate's suitability for employment and decide to whom to offer a job. We may also need to process data from job applicants to respond to and defend against legal claims.

In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, we are required to check a successful applicant's eligibility to work in Malta before employment starts.

We may process special categories of data, such as information about whether or not applicants are disabled in order to make reasonable adjustments for candidates who have a disability. We would process such information to carry out our obligations and exercise specific rights in relation to employment.

Security of Personal Information

NetRefer takes the security of your personal information seriously. We implement appropriate technical, physical, and administrative measures to protect the personal information of job applicants from unauthorized access, disclosure, alteration, or destruction.

Retention Period of Personal Information

We will retain your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed. If the application for employment is unsuccessful, the general rule is that the personal data is erased after 24 months from the date of your original application. Please let us know if you would like us to delete your records before our retention period lapses and we will do so. Notwithstanding the above, specific reasons may necessitate the continuous processing of the personal data, for example, we may process the applications for a longer period to prove that there has been no unlawful discrimination in the selection process, when we consider this necessary.

If you have given us your consent to be contacted for future vacancies at NetRefer, your data will be retained by us until you explicitly withdraw your consent.

If the recruitment process leads to an employment relationship with us, the data you shared with us will become part of your personnel file. It will be stored as long as you are employed by us and thereafter, according to our Employee Privacy Policy.

Your Rights

As a data subject, you have a number of rights. You can:

  • access and obtain a copy of your personal information on request;
  • require NetRefer to change incorrect or incomplete data;
  • request NetRefer to delete or stop processing your data in certain circumstances, for example where the data is no longer necessary for the purposes of processing;
  • object to the processing of your data where NetRefer is relying on its legitimate interests as the legal ground for processing; and
  • ask NetRefer to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override NetRefer’s legitimate grounds for processing data.

If you wish to exercise any of these rights, please contact us at dpo@netrefer.com

Objection and the Right to Complain

To exercise all relevant rights, queries or complaints, please contact us at dpo@netrefer.com

If you are dissatisfied with how we have managed a complaint you have submitted to us, you are entitled to contact your local data protection supervisory authority. As NetRefer operates its business in Malta, it operates under the remit of the Maltese Office of the Information and Data Protection Commissioner.

Change to the Privacy Policy

We may update this Privacy Policy from time to time. Any changes will be posted on our website or communicated to job applicants through other appropriate channels.