Privacy Policy

Last Modified:  1st May 2018
This Privacy Policy is effective from the 25th May 2018.
This privacy policy is made compliant with the General Data Protection Regulation (the “GDPR”), (Regulation (EU) 2016/679) and is therefore also compliant with Directive 95/46/EC and national implementations thereof until they become obsolete on May 25, 2018.

1. Introduction

1.1. As part of any recruitment process, Genesis Global Limited collects and processes personal data relating to job applicants. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.
1.2. This privacy policy is based on the following data protection principles:

  • The processing of personal data shall take place in a lawful, fair and transparent way;
  • 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 they are 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 they are processed, are 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 are processed;
  • All personal data shall be kept confidential and stored in a manner that ensures appropriate security.

2. What information do we collect?

2.1. Genesis Global Limited collects the following information:

  • your name, address and contact details, including email address and telephone number;
  • details of your qualifications, skills, experience and employment history;
  • whether or not you have a disability for which the organisation needs to make reasonable adjustments during the recruitment process;
  • information about your entitlement to work in Malta.

2.2. Genesis Global Limited may collect this information in a variety of ways. For example, data might be contained in your application forms, CVs or resumes, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
2.3. 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.
2.4. The information will be stored in a range of different locations managed by us directly, including human resources management systems and other business applications.

3. Why do we process your personal data?

3.1. We need to process data to take steps at your request prior to entering into a contract with you. We may also need to process your data to enter into a contract with you.
3.2. In some cases, we need to process data to ensure that we are complying with our legal obligations.
3.3. Genesis Global Limited 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 in the exercise and defense of legal claims.
3.4. Genesis Global Limited may process special categories of data, such as details of the applicant’s disability in order to make reasonable adjustments for candidates if necessary.
3.5 We process such information to carry out our obligations and exercise specific rights in relation to employment.
3.6. If your application is unsuccessful, Genesis Global Limited may keep your personal data on file in case there are future employment opportunities for which you may be suited. We will ask for your consent before we keep your data for this purpose and you are free to withdraw your consent at any time.

4. Who has access to your data?

4.1. Your information may be shared internally and externally for the purposes of the recruitment exercise. This includes members of the human resources department, interviewers, managers in the respective business areas and external recruiters (if they supplied us with your information).
4.2. We will not share your data with any third parties (unrelated to the recruitment process), unless you provide us with your explicit consent.

5. How do we protect your data?

5.1. We take the security of your data seriously. We have controls and internal policies in place to protect your data against loss, misuse and unauthorized access, alteration, disclosure, or destruction. Moreover, all efforts are being taken to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and services processing personal information.
5.2. If we learn of a security systems breach, we will inform you of the occurrence of the breach in accordance with applicable law.

6. For how long do we keep your data?

6.1. If your application for employment is unsuccessful, we will hold your data on file for 30 days after the end of the relevant recruitment process. We will ask you for consent to keep your personal data on file for a further 12 months for consideration for future employment opportunities. At the end of that period, or once you withdraw your consent, your data shall be deleted or destroyed. You will be asked to consent when you submit your application for a position via the careers website.
6.2. If your application for employment is successful, the personal data gathered during the recruitment process will be transferred to your personal file stored by the Human Resources department and retained throughout the duration of your employment. Once your on boarding is completed, you will be able to access our Data Retention Policy which defines the retention periods for your and other data.

7. Your rights

7.1. We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided during the recruitment process. As a data subject you have the following rights:

  1. the right for information;
  2. the right to access;
  3. the right to rectification;
  4. the right to erasure;
  5. the right to restrict processing;
  6. the right to object to processing;
  7. the right to data portability;
  8. the right to complain to a supervisory authority; and
  9. the right to withdraw consent.

7.2. If you would like to exercise any of these rights such as accessing, amending or requesting deletion of any information about you, please contact Genesis Global Limited at We will respond to these requests within a month, with the possibility to extend this period for particularly complex requests in accordance with Applicable Law.
7.3. If you believe that the organisation has not complied with your data protection rights, you can complain to the Lead Supervisory Authority’s Data Protection Commissioner.

8. What if you do not provide personal data?

8.1. You are under no statutory or contractual obligation to provide data to Genesis Global Limited during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

9. Data Protection Officer

9.1. Genesis Global Limited has a Data Protection Officer (“DPO”) who is responsible for matters relating to privacy and data protection. Genesis Global Limited’s DPO can be reached at:

10. Changes to this Privacy Policy

10.1. Please note that this Privacy Policy may change from time to time. If we change this Privacy Policy in ways that affect how we use your personal information, we will advise you of the choices you may have as a result of those changes. We will also post a notice that this Privacy Policy has changed, to this page.

To opt out of Genesis Global Limited keeping your details on file please send your request here.