Candidate Privacy Notice

1. JOB CANDIDATE PRIVACY NOTICE

Table of Contents

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1. What is the purpose of this document?
2. Data protection principles 
3. The kind of information we hold about you 
4. How is your personal information collected? 
5. How we will use information about you 
6. If you fail to provide personal information 
7. How we use particularly sensitive personal information 
8. Confirmation of clean criminal record 
9. Automated decision-making 
10. Data sharing 
11. Data security 
12. Data retention 
13. Rights of access, correction, erasure, objection, restriction, and transfer 
14. Right to withdraw consent 
15. Data protection officer 
16. Changes to this privacy notice 

1. What is the purpose of this document?  

Tiffany Investments Ltd / MIM Services Ltd (collectively referred to also as “MYMALL”) are “data controllers”. This means that we are responsible for deciding how we hold and use personal information about you. You are being provided with a copy of this privacy notice because you are applying for work with us. It makes you aware of how and why your personal data will be used, namely for the purposes of the recruitment exercise, and how long it will usually be retained for. It provides you with certain information that must be provided under the General Data Protection Regulation (EC) 2016/679 (GDPR) and applicable data protection laws and regulations (“Data Protection Laws”).

2. Data protection principles  

We will comply with data protection law and principles, which means that your data will be:

• Used lawfully, fairly and in a transparent way;
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
• Relevant to the purposes we have told you about and limited only to those purposes;
• Accurate and kept up to date;
• Kept only as long as necessary for the purposes we have told you about;
• Kept securely.

3. The kind of information we hold about you  

Personal data, or personal information, means any information about an individual from which that person can be identified.

In connection with your application for work with us, we will collect, store, and use the following categories of personal information about you:

• Contact Information: Name, Surname, Email, Address and Telephone Number;
• Other Information: Age, Marital Status, Gender, Date of Birth, Current and Previous Occupation/Employment;
• Identification Information: ID, Passport Number, Photograph, Social Insurance Number, National Tax Identification Number;
• Recruitment Information: including copies of right to work documentation, references and other information included in a CV or cover letter.

This information has been provided to us:

• in your curriculum vitae and covering letter and/or
• via our recruitment agency and/or
• during an interview.

We may also collect, store, and use the following “special categories” of more sensitive personal information about you, which require a higher level of protection:

• Information about your race or ethnicity, religious beliefs, trade union membership;
• Information about your health or disability, including any medical condition, health and sickness records.

4. How is your personal information collected?  

We collect personal information about candidates from the following sources:

• You, the candidate or any other authorized person such as current employee or business associate of Tiffany Investments Ltd / MIM Services Ltd;
• Recruitment agencies;
• Your named referees;
• Data from third parties from a publicly accessible source (e.g. LinkedIn).

5. How we will use information about you  

We will use the personal information we collect about you to:

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

6. If you fail to provide personal information

If you fail to provide information when requested which is necessary for us to consider your application (such as evidence of qualifications or work history), we will not be able to process your application successfully.

7. How we use particularly sensitive personal information  

We will use your particularly sensitive personal information in the following ways:

• We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
• We will use information about your race or ethnicity, religious beliefs, trade union membership, to ensure meaningful equal opportunity monitoring and reporting.

8. Confirmation of clean criminal record  

In specific cases, we may need to ask you for confirmation of a clean criminal record.

9. Automated decision-making  

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

10.  Data sharing

We will share your personal information within Tiffany Investments Ltd / MIM Services Ltd for examining if you are suitable for a position within our Company.

11. Data security  

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breach and will notify you and any supervisory authority of a suspected breach where we are legally required to do so.

12. Data retention  

We normally intend to retain your personal information for a period of twelve (12) months after we have communicated to you our decision about whether to appoint you to a role or not.

We retain your personal information 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. After this period, we will securely destroy your personal information in accordance with Data Protection laws.

13. Rights of access, correction, erasure, objection, restriction, and transfer   

Subject to certain legal conditions, you may have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see Section 14 below).
• Object to the processing of your personal information 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 information for direct marketing purposes.

It is noted that in accordance with the legislation in force, your right to apply for the erasure of your personal data or to object to the processing of your personal data by Tiffany Investments Ltd / MIM Services Ltd is not applicable or may be limited in the following instances where the processing of the data is carried out for the purpose of:

1. establishing, exercising, or supporting legal claims, and
2. maintaining a legal obligation that necessitates the processing on the basis of Cypriot or European Law, to which Tiffany Investments Ltd / MIM Services Ltd is subject.

• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, restrict access to your personal data or request that we transfer a copy of your personal information to another party, please contact the responsible person in writing at dataprotection@mim.com.cy

14. Right to withdraw consent  

You have the right to withdraw your consent for processing your personal information for the purposes of the recruitment exercise at any time. To withdraw your consent, please contact the responsible person in writing at dataprotection@mim.com.cy . Once we have received notification that you have withdrawn your consent, we will no longer process your application and, subject to our retention policy, we will dispose of your personal data securely.

15. Data protection officer

We have appointed a data protection officer (DPO) to oversee compliance with this privacy policy. If you have any questions about this privacy notice or how we handle your personal information, please contact the responsible person at dataprotection@mim.com.cy .

You have the right to make a complaint at any time to the Data Protection Commissioner’s Office, the Republic of Cyprus’ supervisory authority for data protection issues, at:

1 Iasonos Street,
1082 Nicosia, Cyprus
Tel.: +357 22 818 456
Fax: +357 22 304565
E-mail: commissioner@dataprotection.gov.cy

16. Changes to this privacy notice  

We reserve the right to update this privacy notice from time to time to reflect any changes to the way in which we process your personal data or changing legal requirements. In case of any such changes, we will post the updated Mymall Job Candidate Privacy Notice on our website. The changes will take effect as soon as they are posted on this website.