Recruitment Privacy Policy

Whether you are a candidate interested in sharing your CV with us or applying for a specific job, you should read and understand this document detailing Enemed’s recruitment process and how all candidates’ data is processed by the company. Any reference to ‘Enemed’, ‘we’, ‘us’ or ‘our’ in this document refers to Enemed Co. Ltd.

For the purposes of data protection legislation and the personal data you submit on this portal, Enemed is the Controller of such personal data as defined in applicable legislation, in particular the General Data Protection Regulation (Regulation (EU) 2016/679) and the Data Protection Act, (Cap. 568 of the Laws of Malta), and shall process personal data in a fair, lawful and transparent manner in accordance with its legal obligations as contained therein in order to safeguard all rights and protections due to a data subject.

How to show your interest in working for Enemed:

An application for the filling of a vacancy with Enemed can only be processed once Enemed has received a CV of an interested candidate. CVs can only be accepted when uploaded onto the Enemed Careers online portal following the creation of a profile for the candidate via this portal. No CVs are accepted or received by ordinary mail or email. Should Enemed receive any CVs through such means, such candidates shall be referred to the Enemed Careers portal and their CVs immediately deleted.

CVs are received either directly by the candidates or via 3rd Party referrals such as recruitment agencies or current Enemed employees. If you are a referring 3rd party, it is your responsibility to ensure that you have sought the consent of the candidate you are referring prior to sharing their CV with Enemed.

Enemed may also create a recruitment profile for a candidate on the Enemed Careers portal if specifically and legitimately requested to do so.

How Enemed accesses and manages CVs:

All CVs received are placed on a 3rd Party recruitment platform (currently Talexio – more info available here www.talexio.com) via the Enemed Careers portal and stored, accessed and processed there. Talexio is a processor of that information which Enemed receives via this portal and only processes such personal data upon Enemed’s written instructions and in accordance with Talexio’s own legal obligations and its contractual obligations towards Enemed.

Once a candidate’s profile has been created, such candidate would receive an automated email confirmation that such a profile has been created.

Once created, Enemed has access to all candidate profiles and all the information uploaded to or saved in such a profile such as CVs and the candidate’s own notes or comments. Access to this information is granted to relevant Enemed staff on a strict need to know basis.

CVs will only be shared internally and on a need to know basis if considered relevant to the recruitment process for the filling of a known or potential vacancy. Such sharing will only take place using industry standard methods to ensure that your personal data is kept as safe as possible from external interference at all times. Further information can be found below in “How we conduct the recruitment process”.

Unless specifically requested by the candidate in writing or by any other reliable means, Enemed does not modify, in any manner, any profile once uploaded.

How you can access and manage your Profile:

Once created, the candidate shall have access to all the information which they have included and uploaded into their profile and can update it accordingly. The candidate will receive an automated email notification that such a profile has been modified together with instructions to follow should the candidate disagree with such modification or wish to delete or modify their profile once more.

In every email automatically sent by the 3rd party recruitment platform, profile owners will always be reminded of their right to access, object to, suspend, rectify and erase any personal data contained in their profile.

With respect to your right to erase your personal data, please refer to the section on Request the erasure of your personal data for more details.

Retention of CVs and Profiles:

Unless recruited, all candidates shall have their CV kept on the 3rd party recruitment platform for a minimum period of three (3) years to contact candidates about any future positions should we believe that their profile is relevant and matches any new roles. However, this period of three years may start running from the date that the candidate (or anyone authorised to do so on their behalf) shall have last updated their profile. For this reason, you need to know that we too will know when your profile has been accessed or altered by you (or anyone else on your behalf).

We consider that it is in our legitimate interest to retain your CV and profile for such period of time as, when you access your profile without deleting it, we understand that you are still interested in working for Enemed, despite not having been our preferred candidate up until then. Given that most positions carry a probationary period of one (1) year, your continued interest would mean that, should the position you were interested in becoming vacant once again during the probationary period, you may be invited by us to take on the role should you still be interested in doing so.

This amount of time will also allow us to contact you throughout that period in connection with other vacancies of potential interest to you as you continue to progress in your career elsewhere.

During this time, only HR personnel will have access to your profile on behalf of Enemed on a strict need to know basis. When the three year period has lapsed from your last date of access, your profile and all its contents will automatically be deleted. Should you object to the processing or retention of your data as an unsuccessful candidate, you can at any time request that your CV and personal details be deleted from our database in accordance with the section ‘Object to the processing of your data’ below.

How we conduct the recruitment process:

All profiles and CVs specifically received and considered suitable, for any given vacancy will be filtered by our Recruitment Specialist. Access to those CVs which are deemed acceptable by the Recruitment Specialist at this initial stage shall be shared in a secure manner with the interviewing panel and to any other required Enemed personnel on a strict need to know basis. Access to such personal data to non-HR personnel shall only remain active and available until the recruitment process for that vacancy has been satisfactorily filled.

Shortlisting of candidates is done on the basis of the criteria listed in the job description applied for and following a comparison with other interested candidates.

Interviews are conducted on a strictly confidential basis by an internal interviewing panel bound by obligations of confidentiality. If you are an internal candidate and are applying for a vacancy falling under the collective agreement, all rules relating to the recruitment process under the collective agreement shall also apply.

Once a candidate is not on the shortlist or selected, the candidate’s CV is deleted from the 3rd party recruitment platform three years after the closing date of the vacancy. This is due to Enemed’s own contractual obligations with recruitment agencies. This period may be extended if the candidate opts in to keep such CVs and profiles stored indefinitely on the 3rd party recruitment platform via the Enemed Careers portal. The candidate may, however, access, amend and delete their profile at any time at no cost via the Enemed Careers portal. Each candidate shall be reminded of the contents of this paragraph in any communication from Enemed informing such a candidate that their application has not been successful.

Whether or not a candidate decides to opt in for the retention of their profile is entirely their choice and shall have no effect on whether or not such candidate is recruited.

Categories of Personal Data collected:

During the recruitment process, Enemed may collect and process various categories of personal data to assess suitability for employment. This may include, but is not limited to, name, contact details, address, email address, telephone number, date of birth, education and employment history, professional qualifications, skills, references, interview notes, and any other information obtained during the recruitment process.

Additionally, for identity verification purposes, Enemed may collect a successful candidates’ identification document, such as passport or identity card but this is returned and any soft copies shared are deleted once verification takes place.

Sharing with 3rd Parties:

Enemed shall treat all CVs, profiles and applications in strict confidence. No CVs or profiles shall be shared at any point in time outside Enemed except, as explained above, with Talexio which stores, maps and manages your information.

Transfer of data to third party organisations:

Enemed shall take all necessary measures to ensure that personal data is handled securely and in compliance with applicable data protection laws should the recruitment process include transferring data to third party organisation for assessments or other purposes as part of the recruitment process. By engaging in our recruitment process, candidates consent to the transfer of their data as described in this notice. You may submit your objections to processing of your personal data on the grounds of the above mentioned legitimate company interests by contacting our Data Protection Officer. You may do so in writing by email on gdpr.enemed@enemed.com.mt.

Right to Access and Use of Personal Data:

Throughout the duration that a candidate’s profile exists on the 3rd party recruitment platform, Enemed shall only use that information to contact the candidate via email or telephone to inform them of any vacancies that they may be interested in, in line with their profile or as a result of their interview. With every such communication, each candidate shall be asked whether they wish to be contacted again and informed that they may exercise their rights as data subject in accordance with this Privacy Notice and Policy on Recruitment.

Any personnel within Enemed who would have required access to such CVs or profiles to carry out their duties in relation to the recruitment process shall be bound by confidentiality obligations.

If you wish to exercise your right to access the personal data we hold about you or obtain further information about the processing of your personal data, please submit a written request to our Data Protection Officer at gdpr.enemed@enemed.com.mt. We will respond to your request without undue delay and, in any case, within one (1) month from the receipt of the request. In certain circumstances, this period may be extended if necessary, and we will notify you of any such extension.

Request the correction of your personal data:

This means that if any personal information we hold about you is incomplete or incorrect, you have a right to have this corrected. You may access and amend your personal data directly by logging into your public profile from the Enemed Careers portal. However, should you be unable to do so, you may contact the Human Resources Department at Enemed on careers@enemed.com.mt for assistance. We may need to verify your identity and, to do this, may ask you some questions or for you to provide us with some personal details to make sure that we are receiving instructions from the right person.

Object to the processing of your data:

You may object to the collection, use and/or sharing of your personal data if we rely on our legitimate interests (or those of a third party) to do so and you feel that our processing of your data in such a manner impacts your fundamental rights and freedoms. However, in some cases, we may be able to demonstrate that we have a compelling legitimate ground to process your data which may override your rights and freedoms. You may submit your objections to processing of your personal data on the grounds of the above-mentioned legitimate company interests by contacting our Data Protection Officer. You may do so in writing by email on gdpr.enemed@enemed.com.mt.

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 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. You must contact the Data Protection Officer for us to process this request. You may do so in writing by email on gdpr.enemed@enemed.com.mt.

Request the erasure of your personal data (the right to be forgotten):

This means that you may request the erasure of your personal data where we no longer have a legitimate reason to continue using or retaining it. We will not be able to fulfil your request for the first one (1) year from creation of your public professional profile due to our contractual obligations with recruitment agencies. We may not be able to accede also if we are under a legal obligation to retain this information, or where the retention of your information is necessary for us to defend ourselves in a legal dispute or to execute a legal title against you. If you are unable to erase your own data yourself by logging into your profile from the Enemed Careers portal, you must contact the Data Protection Officer for us to process this request. You may do so in writing by email on gdpr.enemed@enemed.com.mt.

Further information:

Should you wish to ask any questions on how Enemed processes or has processed your data or if you would like to make a request to avail yourself of your rights as outlined above, you may do so by contacting Enemed’s Data Protection Officer on gdpr.enemed@enemed.com.mt. You may also contact the Office of the Information and Data Protection Officer to refer any complaints you may have on www.idpc.org.mt or during office hours on Tel 2328 7100.