This Privacy Notice sets out how Royce Tech Ltd (company number C97948), a company duly incorporated under the laws of Malta with registered business address at NOUV, MRO Frank Galea Street, Haz Zebbug, ZBG 9019, Malta, (hereinafter Royce Tech/us/we) collects and processes information about the people who apply to work for us (hereinafter “applicant/you/your), as well as their rights in respect of such personal data.
This Privacy Notice applies to everyone who applies to work for us regardless of whether they are looking to be engaged as partners, employees, workers, contractors or agency staff, and whether they are permanent or temporary staff, whether or full or part time.
We are committed to user privacy and we maintain our commitment by managing your personal data professionally and in compliance with the applicable European data protection regulation and privacy laws.
By continuing to use our recruitment portal or sending us your personal data, you are agreeing to the terms set out in this Privacy Notice and to the use of your personal data in accordance with these terms.
Royce Tech is responsible for the processing of personal data within the meaning of article 4 (7) GDPR as stated in the ‘Job Applicants’ Legal Rights’ section below.
As part of our recruitment process, we will collect and process personal data relating to job applicants. This Privacy Notice is based on the following data protection principles:
As defined under the GDPR, personal data, refers to any information about an individual, through which a person can be identified. During our recruitment process, we may collect personal data directly from the job applicant through our recruitment portal and/or third parties such as recruitment agencies or a referral.
The personal information about you which we expect to collect, hold and use ("process") is likely to include the following. This list is not exhaustive but is intended to give you a clear idea of your personal information which we process:
The information marked in bold is or could include special categories of personal data (as defined under the GDPR and described below in more detail). This information is particularly sensitive, and we will therefore only process this information where necessary. We will ensure that the said information is only seen by those who have to see it and will keep it secure.
In case where you are being referred by an employee (hereinafter “Referrer”) working with us, we will collect the Referrer’s details including name, surname, and job title.
During the interviews, the interviewing panel may take notes and fill out interview guide sheets should this be required.
As part of our recruitment process and depending on the nature of the role, we will require reference letters to be submitted. It is your responsibility to obtain consent from references prior to submitting personal data about them including but not limited to name and contact details.
We do not collect any information about your race or ethnic group, religious beliefs, gender, sexual orientation, political opinion, trade union memberships, and health related information.
We do not share your personal data with outside companies other than for the purposes set out in this Policy and we will not sell or provide your personal data to any company for direct marketing purposes without your consent. Personal data about you may be collected from and provided to and used by the following entities:
We will only use your personal data when the law allows us to. We rely on a number of lawful reasons for processing the information set out above during the recruitment process. Some of the reasons will overlap and there may be several grounds which justify our use of your personal information.
It is in our legitimate interest (the legal basis for processing personal data) to ensure and decide that the right applicants are put through the recruitment process and therefore, choosing the right applicant for the job. Applicants’ consent to process data is necessary, to protect the interest of Royce Tech in case of any claims.
We also process personal data to ensure that we are complying with our legal obligations including employment (hereinafter “Recruitment Process”), anti-discrimination, and data protection laws.
GDPR refers to sensitive data as ‘special categories of personal data’ and include the following types of personal data:
Some special categories of personal data, are processed so that we can perform or exercise our obligations or rights under employment law and in line with our Data Protection Policy, a copy of which may be obtained by request to hr@roycetechnology.com
The job applicants’ personal data may be shared internally for the purposes of the recruitment process with selected personnel such as the hiring manager and members of the human resources department. Your details will be stored in Royce Tech’s online system within the HR online system. No personal data will be shared with third parties for marketing purposes. It is only in the below situations where personal data may be disclosed to third parties only in the following scenarios:
We will use the personal data to conduct due diligence on those we recruit, to ensure we engage the best individual for the job, and to comply with out legal obligations and duties both to you and to regulatory authorities and governmental bodies. In particular, we collect information about you to:
It is in Royce Tech’s legitimate interests to decide whether to appoint you to the role since it would be beneficial to Royce Tech’s business to appoint a suitable candidate to that role. Therefore, Royce Tech also needs to process your personal data to decide whether to enter into a contract with you.
Having received your CV and covering letter and the results from any tests you took (if applicable), Royce Tech will then process that information to decide whether you meet the basic requirements to be shortlisted for the role. If you do, Royce Tech will decide whether your application is suitable to invite you for an interview/s. If Royce Tech decides to call you for an interview, Royce Tech will use the personal data you provide to it at the interview/s to decide whether to offer you the role. If Royce Tech decides to offer you the role, it may then take up references and/or any other check before confirming your appointment.
We take data protection very seriously. If you join Royce Tech, we will provide you with a separate privacy notice regarding your personal data during your work contract with us, and you will also be expected to adhere to our Data Protection Policy which outlines data protection law and how we handle all personal data, including the personal data of our clients, customers, suppliers and contacts.
Retention of job applicants’ personal data will depend on the outcome of the recruitment process. If you are successful in your application to work with us, the personal data will be retained and processed through-out the duration of our work relationship.
If you are unsuccessful in your application to work for us or you choose not to accept the offer of a work contract with us (if applicable), we will retain your personal data for a period of 12 months or such other period as may be required under our legal obligations, subject to the caveat that all emails are stored in our email archiving system for a period of up to 7 years from the date of being sent or received.
We retain your personal data for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way. We further retain such personal data in case a similar role becomes vacant for which you will be a fitting candidate.
Royce Tech retains personal data using technologies and internal policies to protect the job applicants’ personal data against loss, misuse and unauthorised access, alternation, disclosure, or destruction. Furthermore, Royce Tech takes the necessary steps and procedures to ensure confidentiality, integrity, and resilience of systems are not breached.
Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. You will not be subject to conclusions that will have a significant impact on you based solely on automated decision-making.
In relation to personal data, as a data subject, the job applicants’ legal rights include:
To exercise any of these rights and/or to ask regarding matters relating to the recruitment process, please contact the Human Resources Department by sending an e-mail to hr@roycetechnology.com. Royce Tech will respond to requests within one (1) month unless the matter is complex, or a number of requests are made.
As a job applicant, you are under no obligation to provide personal data during the recruitment process however, if you fail to provide such information, we may not be able to proceed with your application.
If you consider that the processing of your personal data is carried out in an unlawful manner, you may lodge a complaint with the Information and Data Protection Commissioner by sending an email to idpc.info@idpc.org.mt
We may need to request specific personal data from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
This Privacy Notice may change from time to time. Should the changes affect how we use personal data, the job applicants will be informed accordingly and provided with a choice.
By submitting your personal data, you shall:
