Privacy policy

This privacy policy provides a framework for the processing of personal data by Manpower Malta in accordance with the provisions of the General Data Protection Regulation of the European Union (hereinafter referred to as “GDPR”) and the Data Protection Act (Chapter 586 Laws of Malta).

Data Controller

The Data Controller is Innovative Workforce Solutions Limited.

Farrugia Apartments, 3, San Mikiel Street, San Gwann Malta (Europe). Registration Number C74158

The personal data collected will be controlled and processed by the Data Controller.

Whom does the Privacy Policy apply to?

• The Privacy Policy applies to users of this website and any applications listed here.

This privacy policy describes the types of personal data or personal information we collect through this website, how we use the information, how we process and protect the information we collect, for how long we store it, with whom we share it, to whom we transfer it and the rights that individuals can exercise regarding our use of their personal data. We also describe how you can contact us about our privacy practices and to exercise your rights. Our privacy practices may vary among the countries in which we operate to reflect local practices and legal requirements and you can view specific local terms by going to local websites.

When you visit our www.manpowergroup.com.mt website, we make use of cookies as detailed in our Cookie Policy.

1. Information We Collect

We may collect personal data about you through your use of this website. We may collect a selection of personal data dependent on the nature of the relationship, including but not limited to (as permitted under local law):

• Contact information (such as first, middle and last name);
• Contact details (such as your private home address, e-mail address, mobile and telephone number);
• Other information you may provide to us through the ‘Contact Us’ feature on the website.

If you apply for a vacancy, we may collect different types of personal information, to the extent permitted by national law. We invite you to read our Candidates’ Privacy Policy if you are applying for a vacancy through this website.

2. How We Use the Information We Collect

The Controller collects and uses the data gathered for the following purposes (as permitted under local law):

1. responding to individuals’ inquiries and claims;
2. operating, evaluating and improving our business (including developing, enhancing, analysing and improving our services; managing our communications; performing data analytics; and performing accounting, auditing and other internal functions);
3. protecting against, identifying and seeking to prevent fraud and other unlawful activity, claims and other liabilities;
4. complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies;
5. where permitted under law and only if you have given your consent, to communicating about, and administering participation in, special events, promotions, programs, offers, surveys, contests and market research;

The processing of data is carried out on the following grounds:

1. the clear consent from the data subject;
2. ensuring that we comply with the statutory and contractual requirements, and/or requirements necessary to enter into a contract. You are obliged to provide this data and if this data is not provided we will be unable to provide you with our services;
3. it is essential and necessary for the legitimate interest of the Data Controller e.g. letting the user access the website to be provided with the services offered. Please see our section on Legitimate Interests below to learn more about these interests and when we may process information in this way.

3. Legitimate Interest

The Data Controller may process personal data for certain legitimate interests. One of these legitimate interests include the legitimate business purpose and includes the following:

• to identify and prevent fraud;
• to enhance the security of our network and information systems;
• to better understand how people interact with our websites;
• to send you communications that we think are of interest to you;
• to determine the effectiveness of advertising campaigns and advertising;
• to improve, modify or personalise our services and communications with our customers, applicants and employees.

When we process data for these purposes, we ensure that we respect your rights and keep such rights in high regard. You have the right to object to such processing and if you wish to do so kindly send an email to ­data.protection@demajo.com.

4. How We Process and Protect Personal Information

We process personal information for the purposes and for a specified period of time to ensure personal information is not stored longer than necessary.

We provide administrative, technical and physical security measures to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

To ensure the appropriate security and confidentiality of your personal information, we use the following security measures:

• encryption of data during transmission;
• strict user identification controls;
• protected network infrastructure;
• network monitoring solutions.

5. How Long We Store the Data We Collect

In our system, we will store your personal data for a period of five (5) years from your first subscription to our services.

We have determined this period by taking into account:

• the need to continue to store the personal data collected in order to provide user-provided services;
• the need to protect the data controller’s legitimate interest as described in the purposes;
• the existence of specific legal (national) obligations that make processing and associated storage necessary for certain periods of time.

6. Data That We Share With Third Parties

We transfer personal data only in accordance with this privacy policy. We do not disclose personal data that we collect about you except as described in this privacy policy or in separate notices provided in connection with particular activities.

We also may share your personal data (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government officials based on a lawful disclosure request; and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer personal data we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

7. Data Transfers

We may also transfer personal information to recipients in countries other than the original country of collection.

These countries may not have the same data protection laws as the country where the personal information was originally provided. If we transfer data to other countries, we will protect that information as described in this Privacy Policy, and such transfers will be governed by applicable law.

Countries to which we may share personal information may be located inside or outside the European Union.

When we transfer personal data from the European Union to countries or international organizations outside the European Union, such transfers shall be based on:
In order to ensure the protection of your data, we implement at least one of the following safeguards:

• Adequacy decision – we ensure that we transfer your personal data to countries providing an adequate level of protection according to the European Commission;
• US / Swiss Privacy Shield – where the Data Processors we use are based in the United States of America or Switzerland, we try to ensure that such Data Processors are approved under the Privacy Shield. This Privacy Shield ensures that the Data Processors provide similar protection to personal data shared between the EEA and the United States or Switzerland;
• Standard clauses – where the Data Processor is not based in a country benefiting from an adequacy decision or is not part of the US/Swiss privacy shield, as explained in (i) and (ii) above, we may use specific contracts, known as standard contract clauses, which are model contracts approved by the European Commission. These contracts also ensure that the personal data is afforded the same protection as it is in the EEA;
• Legally binding and enforceable instrument between public authorities or bodies;
• Binding internal company rules.

8. Your Rights as Data Subject

Data protection law gives you, as a data subject, certain rights in certain circumstances.  In accordance with law, you have a right to:

Request access to your personal data – This means that you have a right to request, free of charge, a copy of the personal data we hold about you;

Request the correction of your personal data – This means that if any personal data we hold about you is incomplete or incorrect, you have a right to have this corrected. In such case, we may need you to provide evidence and documentation (such as your ID documentation or proof of address) to support your request;

Request the erasure of your personal data – This means that you may request the erasure of your personal data where we no longer have a legitimate reason to continue processing it or retaining it. This right is not absolute – in certain cases, such as when we are obliged under a legal obligation to retain the data, or where we have reasoned that the retention of data is necessary for us to defend ourselves in a legal dispute, we would not be able to accede to your request;

Object to the processing of your personal data – you may object to the processing of your personal data in cases where we rely on our legitimate interests (or those of a third party) to process your data and you feel that our processing of your data in such a manner impacts your fundamental rights and freedoms. However, we may be able to demonstrate that we have a compelling legitimate ground to process your data which may override your claims. You may submit your objections to the processing of your personal data on the grounds of the above-mentioned legitimate company interests by contacting our Data Protection Officer;

Request the restriction of the processing of your personal data – You may ask us to temporarily suspend the processing of your personal data in one of the following scenarios: (a) where you want us to establish the accuracy of the data, (b) where you claim that our use of the data is unlawful but you do not wish for us to delete it, (c) where you need us to retain your data even when we no longer need it in order for you to establish, exercise, or defend legal claims, or (d) where you have objected the use of your data but we need to verify whether we have overriding legitimate grounds to use it;

Request the transfer of your personal data – This means you may request us to transfer certain data we process about you to a third party. This right only applies to data acquired through automated means which you initially provided for us to use, or where we used the data to perform our obligations under a contract with you;

Withdraw your consent at any time where we rely on your consent to process the data – ‘Opting out’ or withdrawing your consent will not affect the lawfulness of the processing carried out by us up until the time you withdrew your consent. Withdrawing your consent means that, going forward, you no longer wish for us to process your data in such a manner. This means that you may no longer consent for us to provide you with certain services (such as marketing);

File a complaint with a supervisory authority – In case you face difficulties, we invite you to contact our Data Protection Officer by any means so that we can make all possible efforts to resolve any problem that you may have.

However, should you consider at any time that we are handling your personal information in a manner that leaves you dissatisfied or at a disadvantage, you may at any time file a complaint with the Office of the Information and Data Protection Commissioner by email on idpc.info@idpc.org.mt, by ordinary mail at Information and Data Protection Commissioner, Level 2, Airways House, High Street, Sliema, SLM 1549, Malta or by calling (+356) 2328 7100.
In order to exercise your rights as explained above, we may need to request specific information about you to help us verify your identity. This is a security measure to ensure that we are certain that the person to whom we disclose your personal data is really you.

We aim to respond to all legitimate requests within one month from the submission of a request. If your request is particularly complex, or if you have made multiple requests concurrently, it may take us a little longer. In such a case, we will notify you of this extension.

For more information please feel free to contact our Data Protection Officer (DPO) by email at data.protection@demajo.com, by phone at +356 2552 0000, and by mail at Data Protection Office, Demajo House, 103, Archbishop Street, Valletta VLT 1446.

Updates to Our Privacy Policy

This Privacy Policy may be amended from time to time. Any significant changes will be indicated on our website and/or by sending you a notification via your contact information. We advise you to review this Privacy Policy whenever you use our website to remain properly informed.