Introduction: NetRefer Respects your Privacy.

This privacy statement 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. We will handle your personal data in a careful, secure and confidential manner. This privacy statement explains how we do this. This privacy statement supplements our existing Privacy Policy, which gives you specific information on how we process personal data obtained from you visiting our website.

What Personal Data do we Collect?

If you apply for a position at NetRefer, we collect the following information about you:

• your name, address and contact details, including email address and telephone number;
• details of your qualifications, skills, experience and employment history;
• information about your current and desired levels of remuneration, including benefit entitlements;
• where required by local law, information about your entitlement to work in the country where we are hiring;
• other relevant information related to a specific job opening.

We may collect this information in a variety of ways. For example, data might be contained in application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.

We may also collect personal data about you from third parties, such as references supplied by former employers. We will seek information from third parties only once a job offer to you has been made and will inform you that we are doing so.

We may also collect the following special categories of your personal information during the recruitment process (as applicable):

• 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.

Data 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).

Why do we Collect Personal Data?

We process your personal data for the purposes of carrying out the recruitment process, which includes:

• Assessing your skills, qualifications and interests against our career opportunities;
• Verifying your information and carrying out reference checks and/or conducting background checks (where applicable) if you are offered a job;
• Communications with you about the recruitment process and/or your application(s), including, in appropriate cases, informing you of other potential career opportunities at NetRefer;
• Creating and/or submitting reports as required under any local laws and/or regulations, where applicable;
• 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;
• Complying with applicable laws, regulations, legal processes or enforceable governmental requests; and/or
• 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.

We will also use your information to protect the rights and property of NetRefer, our users, applicants, candidates, employees or the public as required or permitted by law.

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.

Legal Grounds for Processing

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 Data

NetRefer takes the security of your personal data seriously. We have internal policies and controls in place in line with applicable legal requirements and guidelines, to ensure that your data is not misused or disclosed, and is not accessed except by our personnel in the proper performance of their duties.

Retention Period of Personal Data

We will only store your personal information for as long as is necessary to fulfil the purposes for which it was collected and processed.

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 7 years thereafter, unless the law prescribes a longer retention period.

If the application for employment is unsuccessful, the general rule is that the personal data is erased after 12 months from the date of your original application. 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.

Where is your Personal Data Processed?

We will process your personal data in the European Union/EEA. Your personal data could be processed in or passed on to countries outside the European Union/EEA, but only if there are appropriate safeguards in place to secure your personal data.

Who has Access to your Data?

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.

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 and cloud hosting providers. If your application for employment is successful and we make you an offer of employment, we may share your data with third parties to obtain references and any employment background checks needed for your employment.

Change to our Policy

This privacy statement may be amended from time to time.

Your Rights

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

• access and obtain a copy of your data 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.