1. Introduction
This Privacy Policy (the “Policy”) relates to the services provided by AIMS International Malta Limited (“AIMS International Malta”), a private limited liability company registered in Malta bearing company registration number C94480 and having its registered office at 168, St Christopher Street, Valletta VLT 1467, Malta.
AIMS International Malta respects your privacy and wants to ensure that your Personal Data is protected. AIMS International Malta applies all reasonable measures to ensure that the Personal Data processed is limited to those necessary for the processing purposes related to this Policy.
This Policy provides you with all the information you need to know about how AIMS International Malta (“Data Controller”/ “Data Processor”) collects, protects and safeguards your Personal Data ("Data Subject") and your rights in relation to the Personal Data you provide. The applicable law with which AIMS International Malta complies with in this regard is the General Data Protection Regulation (EU)679/2016, which came into effect on May 25th, 2018.
This policy may be amended or updated from time to time to reflect changes in our practices in relation to the processing of Personal Data or changes in applicable law.
Our full details are as follows:
Contact details
Full name of legal entity: AIMS International Malta Limited
Email address: [enquiries@aims-malta.com]
Registered address: 168, St Christopher Street, Valletta VLT 1467, Malta
2. Personal Data Collection Points
We may collect personal information about you, such as your name, address, and contact information. Examples of sources from which we collect Personal Data include:
- Directly from you e.g. when you contact us by email/phone, by providing your CV to us or by any other means
- From our existing relationship e.g. if we offer to link you with our customers
- From other members of the AIMS International Malta corporate network as long as they provide them to us
- Data that you choose to share on other platforms, including social media e.g. we may collect information from your social media profiles as long as you have set them as public information on those mediums.
- From third parties who provide them to us e.g. former employers
- Third party Personal Data provided by you: In some cases, you may disclose Personal Data of other third party individuals. For example, you may act as a source of information and comment on a candidate. Whenever you provide us with any such Personal Data, we rely on you to verify that you have the legal basis to disclose that Personal Data to us and that you comply with applicable law as well as with the terms of this policy. If you are unable to do so, please refrain from providing us with any third party Personal Data.
3. Types of Personal Data Processed
Personal details: name(s), gender, date of birth/age, citizenship, photo, marital status, job title, employer, department, details of wages and benefits
Contact details: home address, work address, home phone number, work phone number, personal mobile phone number, personal email address, work email address and social media profile details
Employment background: dates and details of current and former jobs, details of current and former employers, dates of employment, job titles, job positions, experience in the field and details of any disciplinary or employment incidents
Information of individuals who have provided letters of recommendation(s): details of the recommendations that will be provided, including the relationship you may have with each of these, as well as the duration of this relationship
Background checks: details disclosed by background checks conducted in accordance with applicable law and subject to your prior express written consent, including details of prior employment, residence details, recommendation checks
Invoicing information: when managing invoices/payments for customers, suppliers and outsourcers, we may process financial information, such as tax IDs, invoicing address, contact details and bank accounts
If you apply for a job with AIMS International Malta, we will collect, process and store the information you have sent us for recruitment-related purposes, such as contacting you. Additionally, AIMS International Malta may keep your data for a period of time for the purpose of considering you for a different opportunity.
4. Purpose and Legal Basis for the Processing of Personal Data
When processing Personal Data for the purposes set out in this Policy, we may rely on one or more of the following legal bases:
- We have obtained your prior explicit consent to “process” the data (this legal basis is used only in relation to “processing” which is completely optional – not to be used in cases where the processing is legally necessary or mandated in any other way)
- “Processing” is necessary for the performance of any contract with which you may enter into with us
- “Processing” is mandated by applicable law
- “Processing” is necessary to protect the vital interests of any individual, or
- We have a legitimate interest in performing the “Processing”, which does not in any way violate any of your interests, fundamental rights or freedoms
Whenever we rely on this legal basis, our legitimate interests are as follows:
- Our legitimate interest in managing and carrying out our business activities
- Our legitimate interest in promoting our business and
- Our legitimate interest in providing services to our customers
AIMS International Malta is a consulting company dedicated to providing services in the field of Executive Search, Direct Search, Advertised search and selection, Multi-country search and Talent Management. In view of the foregoing, the purposes for which we may process Personal Data in accordance with applicable law include:
- Search, Headhunting and Evaluation Activities on behalf of clients: hiring executives, promoting our clients’ job opportunities, keeping records and performing career audits;
- Communication and Briefing: communicating with you by any means (including email, telephone, text message, social media, in-person contact) regarding issues that may relate to you or may be of interest to you or for the purpose of obtaining market information;
- Communication, management and processing of invoices, payments and accounting of financial data (invoices, contract documents) of customs, suppliers and affiliates
Personal Data is processed as part of AIMS International Malta’s normal activity in order to carry out an objective and qualified assessment of the professionalism acquired by the Data Subject who provides such data, depending on the role for which a personnel selection procedure is underway (purpose "candidate selection"). The data may also be stored and used at a later date, for the execution of any further selection operations.AIMS International Malta’s mission is to bring together supply and demand for skilled labour.To pursue the aim of "candidate selection", the legal basis is the legitimate interest of the Data Controller.On the one hand, AIMS International Malta helps people who are looking for a job, or a new professional opportunity, for example by responding to offers posted on this site, by posting a CV on a job board or on a networking site. On the other hand, AIMS International Malta offers personnel search and selection services to companies that need new qualified profiles.
AIMS International Malta collects and uses the Personal Data of Data Subjects, thus operating as an organization that pursues a legitimate interest in terms of efficiency, professionalism and ability to be remunerative. In doing so, it also acts in the interest of people who apply, or are interested in new professional opportunities. AIMS International Maltaensures at all times the right of the Data Subject to object to processing based on legitimate interest.
5.Category of subjects to whom the data may be communicated
AIMS International Malta needs to communicate the Personal Data provided to:
- third parties who will process the data as data controllers, for example, companies that commission AIMS International Maltato recruit personnel to be included in their workforce.
- third parties, specifically appointed as data processors, who will process the data with the sole purpose of ensuring, through the provision of tools, applications, technical infrastructures and evaluation platforms, the execution of the services provided by AIMS International Malta.
- AIMS International Malta staff, internal and external consultants, who carry out processing activities as subjects authorised by the Data Controller.
- competent authorities for any fulfilment of legal obligations and/or provisions of public bodies, upon request.
Due to the international nature of our business, we may require to transfer Personal Data to other entities of the AIMS International Malta network. For this reason, we may transfer Personal Data to other members of the AIMS International Malta network located in other countries which may have different laws and data protection requirements than those in force in Malta. If we transmit Personal Data to other countries, we do so by obtaining your express consent on a case-by-case basis and it is done to the extent appropriate, in relation to the client opportunities for which you are a candidate. During all data transfers, we always take all appropriate measures so as to ensure that the transmitted data are the minimum required for the intended purpose and that the conditions for legitimate and lawful processing will always be met.
6. Data Retention Period
The Personal Data collected will be stored in a form that allows the identification of the Data Subject for a period of time not exceeding the achievement of the purposes for which they are collected and processed. At the end of the retention period, the data will be deleted from AIMS International Malta systems and document archives, unless laws or other regulations to which it may be subject require retention for longer periods. The maximum retention period is five years from the last interactive contact. This period corresponds to a professional cycle that will allow AIMS International Maltato follow the Data Subject in his/her career development with relevant and evolutionary professional proposals.
7. Methods of Data Processing
The data voluntarily provided by the Data Subject for the purposes indicated above will be processed by means of both manual and computerized archiving. The sending of the CV to AIMS International Maltaby the Data Subject, if not done through the online form of the www.aims-malta.com/jobswebsite, must include the authorization for the processing of Personal Data by AIMSInternational Malta.
The processing of data collected through the website www.aims-malta.com/jobsor provided to AIMS International Malta by post, fax, e-mail, takes place at the Data Controller's headquarters and is carried out by persons authorised to process it, or by external parties appointed as Data Processors identified by AIMS International Malta.
8. Navigation data & Cookies
Generally, during normal Internet browsing, some Personal Data may be implicitly collected, such as IP addresses or computer domain names and other parameters relating to the user's operating system and computer system. This data is not used by AIMS International Malta except anonymously and only to obtain statistics on visits to its site.
No Personal Data of users is acquired by the site. Cookies are not used for the transmission of personal information, nor are persistent cookies of any kind used, or systems for tracking users.
The use of session cookies (which are not stored permanently on the user's computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow safe browsing of the site and to allow better use.
The session cookies used on the AIMS International Malta website avoid the use of other IT techniques that could potentially compromise the confidentiality of users' browsing and do not allow the acquisition of Personal Data identifying the user.
9. Rights of the Data Subject
The Data Subject may assert his/her rights as established by the GDPR, by contacting AIMS International Malta Limited directly, with registered office at 168, St Christopher Street, Valletta, VLT 1467, Malta by writing to the following e-mail address: enquiries@aims- malta.com
The Data Subject has the right, at any time, to:
- obtain access to the Personal Data from the Data Controller and request information relating to the purposes, the categories of Personal Data processed, the recipients to whom the Personal Data will be communicated (including any recipients in third countries), the period for which the Personal Data will be stored or, where this is not possible, the criteria for its definition, the existence of an automated decision-making process, including profiling;
- rectify, erase Personal Data or restrict its processing. If the Data Subject has given consent to the processing of Personal Data concerning him or her for one or more specific purposes, he or she may revoke consent at any time;
- be informed of the existence of adequate safeguards relating to the transfer of your data to a third country or to an international organisation;
- request portability of Personal Data; in this case, the Data Controller will provide the Personal Data of the Data Subject, in a structured, commonly used and machine-readable format, transmitting them to another Data Controller, if requested;
- object, for reasons related to your situation, to the processing of Personal Data even if such processing is based on the specific needs of the Data Controller. The Data Controller therefore refrains from further processing, unless it demonstrates: 1. the existence of compelling legitimate reasons that prevail over those of the Data Subject, or, 2. the existence of an investigation, exercise or defence of a right in court;
- not be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you;
- lodge a complaint with a supervisory authority, in the event that the Data Subject considers that the processing of Personal Data violates the provisions of the GDPR, without prejudice to any other administrative or judicial remedy.
You have the right to lodge a complaint at any time to a competent supervisory authority on data protection matters, such as in particular the supervisory authority in the place of your habitual residence or your place of work. In the case of Malta, this is the Office of the Information and Data Protection Commissioner (the “IDPC”) (https://idpc.org.mt/). We would, however, appreciate the opportunity to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.