Privacy Notice


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.

Data Controller and contact details

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.

Data protection principles

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:

  • The processing of personal data shall take place in a lawful, fair and transparent manner;
  • The collection of personal data shall only be performed for specified, explicit and legitimate purposes and will not be further processed in a manner that is incompatible with those purposes;
  • The collection of personal data shall be adequate, relevant and limited to what is necessary in relation to the purpose for which the personal data is being processed;
  • The personal data shall be accurate and where necessary, kept up to date;
  • Every reasonable step shall be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without delay;
  • Personal data shall be kept in a form which permits identification of the data subject for no longer than it is necessary for the purpose for which the personal data is processed;
  • All personal data shall be kept confidential, secure and protected against unauthorised or unlawful processing and against loss or destruction and stored in a manner that ensures appropriate security.

Collection of personal data (about the job applicant)

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 personal data you have provided to Royce Tech in your Curriculum Vitae (hereinafter “CV”) and the information contained in your covering letter.
  • The information you have provided on our application form, including name, title, home address, telephone number, personal email address, date of birth, employment history, qualifications, nationality, social media accounts, profession, professional memberships, educational achievements, diplomas, transcripts, languages, computer skills, national service completion (if applicable), identification number and any information you provide us during interviews with Royce Tech;
  • Your current work contact details including telephone numbers, and email addresses;
  • Reason for leaving previous employment(s);
  • Any personal data provided to us about you by your referees, this could include information about the capacity in which the referee knows you; how long they have known you; length of service; absence (including sickness absence); any disciplinary investigations and proceedings, whether or not any disciplinary action was taken; details of any grievance investigations or complaints raised by you, or by a third party about you, whether or not any action was taken; your performance, attitude and personality;
  • Information on any unspent criminal convictions. We will only collect information about criminal convictions or alleged commission of offences if it is appropriate given the nature of the role and where we are legally able to do so;
  • Further information you provide such as hobbies, interests outside work and achievements;

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.

How we share personal data

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:

  • Recruitment agencies;
  • Our outsourced psychometric testing provider;
  • Our outsourced recruitment platform provider;
  • Online job applications;
  • Our associated companies;
  • Courts and tribunals where necessary for establishing or defending legal claims; and
  • Other third parties where we have a legitimate reason to share it and have put the necessary safeguards in place to protect your personal data.

How we will use personal data about you

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.

Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract, we have entered into with you.
  • Where we need to comply with a legal obligation.
  • Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.

We may also use your personal data in the following situations, which are likely to be rare:

  • Where we need to protect your interests (or someone else's interests); and
  • Where it is needed in the public interest or for official purposes.

Processing personal data

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.

Special categories of personal data

GDPR refers to sensitive data as ‘special categories of personal data’ and include the following types of personal data:

  • Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs and trade union membership;
  • Genetic or biometric personal data; and
  • Personal data concerning health, sexuality or sexual orientation.

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

Access to personal data

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:

  • Compliance with legal obligations or contracts, or to respond to a court order, administrative or judicial process, such as a subpoena or search warrant.
  • In response to lawful requests by public authorities.
  • As necessary to establish, exercise or defend against potential, threatened or actual litigation.
  • Where necessary to protect Royce Tech’s interest, job applicants’ interest or those of any other person or in connection with the sale, assignment or other transfer or all or part of the business.

How will Royce Tech use personal data about you?

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:

  • Assess your skills, qualifications, and suitability for the role.
  • Carry out background and reference checks, where applicable.
  • Communicate with you about the recruitment process.
  • Keep records related to our hiring processes.
  • Make reasonable adjustments; and
  • Comply with legal or regulatory requirements.

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 personal data and data security

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

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.

Job Applicants’ Legal Rights

In relation to personal data, as a data subject, the job applicants’ legal rights include:

  • The right to information about the collection and use of your personal data;
  • The right to access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
  • The right to rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
  • The right of erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below);
  • The right to withdraw consent to the collection, processing and transfer of your personal data for a specific purpose (if applicable);
  • The right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.;
  • The right to request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it;
  • The right to object to automated processing of your personal data. This grants you the right to object to a decision based on an automated processing;
  • The right to request transfer of your personal data to another party; and
  • The right to data portability of your personal data. This enables you to obtain and reuse your personal data or your own purposes across different services,

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 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

What we may need from you

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.

Changes to the Privacy Notice

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:

  • Declare that you have received, read, understood and accepted the information set out in this Privacy Notice.
  • Declare that you  understand that you are voluntarily providing personal information and that:
  • the information given by you to Royce Tech is complete and true to the best of your knowledge and understand that incorrect statements could lead to you application being rejected.
  • consent was obtained from any third party whose details are included in the information provided.
  • you authorise Royce Tech to verify statements contained in your application and to make any necessary checks.
  • Declare that you authorise Royce Tech to collect from and provide some of the information to certain external companies as set out in this Privacy Notice above who provide services to Royce Tech and its staff for the purposes of progressing your application to work with Royce Tech.