1. Privacy Policy

Our Privacy Policy (this “Policy”) is made compliant with the General Data Protection Regulation (the “GDPR”), (Regulation (EU) 2016/679) and with the Data Protection Act (Cap. 586) of the Laws of Malta, (collectively referred to as the “Applicable Legislation”).

One of your rights under Applicable Legislation is that you must be informed when an organisation is Processing your Personal Data.  You also have the right to know the details and purpose of that Processing.

Quad Consultancy (Malta) Limited of 5, Triq il-Ħuttaf, Mosta MST 4601, Malta (“Quad Consultancy”), which shall be the data controller for the purpose of Applicable Legislation for the Processing of Personal Data during the normal course of its business relating to natural persons, including but not limited to, its employees, contractors, suppliers, service providers, advisers and clients and also the Processing of Personal Data undertaken through www.quadconsultancy.com  (the “Website”). This Website and all site-related content and/or other websites including the Fora website and social media platforms (collectively, the “Sites”) are being made available subject to your compliance with this Policy.

This Policy covers Quad Consultancy’s treatment of Personal Data that is collected when you are on the Sites, when you are employed with Quad Consultancy, when you use Quad Consultancy’s Services or supply any service to Quad Consultancy as well as any other access and/or use of the Sites.

 

2. Definitions

“Data Subjects” mean an identified or identifiable natural person to which any particular Personal Data relates to. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person

“Personal Data” means information that specifically identifies an individual or that is linked to information that identifies a specific individual.

“Processing” means any operation or set of operations which is performed on Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making information available, alignment or combination, restriction, erasure or destruction (and ‘Process’, ‘Processed’, ‘Processing’ etc shall be construed accordingly).

The Term “you” as used herein refers to all individuals including but not limited to employees, contractors, suppliers, service providers, advisers and clients such as career seekers, employers and their personnel, members of the Fora website, or the general public, doing business or establishing contact with Quad Consultancy and/or accessing the Sites.

 

3. Quad Consultancy’s Obligations

In line with Data Protection principles, Quad Consultancy shall ensure that:

  • Personal Data is Processed fairly, lawfully and in a transparent manner;
  • Personal Data is only collected for specified, explicit and legitimate purposes;
  • Personal Data that is Processed is adequate, relevant and limited to what is necessary in relation to the purposes of Processing;
  • Personal Data is accurate, and, where necessary, kept up to date, with every reasonable step taken to ensure that Personal Data that is inaccurate is erased or rectified without delay;
  • Personal Data is kept in a form which permits identification of Data Subjects for no longer than is necessary, having regards to the purposes for which it is Processed; and
  • Personal Data is Processed in a manner that ensures appropriate security, including protection against unauthorized or unlawful Processing and against accidental loss, destruction or damage, using appropriate, technical or organisational measures.

 

4. Processing of Personal Data

Quad Consultancy is an HR and Recruitment Specialist providing related services (Services), and for these purposes we collect a variety of Personal Data necessary to operate and to provide such Services in a secure and highly confidential environment.  Quad Consultancy Processes Personal Data about its employees, contractors, suppliers, service providers, advisers and clients, including but not limited to career seekers, employers and their personnel, members of the Fora website and general website visitors.

Your Personal Data shall be Processed primarily for the purposes of your legal relationship with Quad Consultancy i.e. due to your employment relationship (if you are an employee), due to your service agreement (if you are a service provider, contractor or supplier), due to your engagement agreement (if you are an adviser), due to an HR and/or recruitment agreement (if you are a client) or due to other agreements including but not limited to confidentiality agreements (if you are a member of our Fora website).

Quad Consultancy may Process Personal Data if the Data Subject has unambiguously given consent, whereby Consent of the Data Subject means any freely given (i.e. if the Data Subject has a genuine or free choice to refuse or withdraw consent without detriment), specific, informed and unambiguous indication of the Data Subject’s wishes by which he, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to him.

Where Processing is based on Consent, Quad Consultancy shall be able to demonstrate that the Data Subject has consented to Processing of his Personal Data.

For the purposes of this Policy, for Consent to be binding:

  • The Data Subject should be aware that Quad Consultancy is collecting this data;
  • It must be given by a statement or by a clear affirmative action confirming that Consent has been expressly given (i.e. no pre-ticked boxes); and
  • If the Data Subject’s Consent is given in the context of a written declaration which also concerns other matters, the request for Consent shall be presented in a manner which is clearly distinguishable from the other matters, in an intelligible and easily accessible form, using clear and plain language.

The Data Subject shall have the right to withdraw his Consent at any time and shall be informed of this right.

Personal Date which reveals race, ethnic origin, political opinions, religious or philosophical beliefs, membership of a trade union, the Processing of genetic data, biometric data, health, sex life or sexual orientation (Sensitive Personal Data) may only be Processed by Quad Consultancy:

  • Upon the explicit Consent of the Data Subject, or
  • If such data has been made public, and
  • If Quad Consultancy adopts appropriate safeguards and the Processing is necessary in order for Quad Consultancy to comply with duties or to exercise rights under any law that regulates employment conditions, or the vital interests of the Data Subject or of some other person will be able to be protected and the Data Subject is physically or legally incapable of giving Consent, or legal claims will be able to be established, exercised or defended.

 

More specifically with regards to the Processing of Personal Data of specific Data Subjects, please refer below:

 

Career seekers

Your Personal Data is processed by us for the purposes of our legal relationship.   In particular, we collect your Personal Data in order to enable us to:

  • match your skill sets with job vacancies to assist in finding you the position that suit you best;
  • Share your details to our clients and prospective employers for you to be considered for vacancies;
  • Provide you with the opportunity to gain employment with our clients and prospective employers;
  • keep you informed of available opportunities as they arise;
  • contact you about service-related announcements.

 

In the case of job alerts, we will only do this with your permission and to keep you up to date. If you do not wish to receive job alerts from us you have the option to disable the job alerts, whereby you would be accepting to not receiving any job alerts.

Please note further to our sharing of your Personal Data with prospective employer/s, the manner in which any of your Personal Data is processed by prospective employer’/s is the sole responsibility of that prospective employer/s.  The deletion of your CV sent to any prospective employers through the Quad Consultancy portal, by way of example, will be at the discretion of the prospective employer/s. If you wish to have this information deleted or have any other questions, you may contact the prospective employer/s or refer to their privacy policy.

 

Employers and their Personnel

In particular, we collect your Personal Data in order to enable us:

  • To advertise your vacancies;
  • To link to Career seekers via the platform who are the right fit for you or your organisation; and
  • To contact you about service-related announcements.

 

Fora Members’ Website

Our primary purpose for collecting Personal Data about you or members of our Fora website is to provide you with the opportunity and required support to network and share knowledge, resources and ideas with other members.

We will ensure that this Personal Data is only processed with your permission and you may wish and we will comply with your clear instructions, to have all or some of your Personal Data visible on the Fora Website and should you wish to have your details updated or removed at any time then you can contact our Principal Contact identified in this Policy who will arrange to have your Personal Data updated accordingly.

 

General Website Visitors 

In the majority of the time, we will be processing your contact details and history in order to answer your queries as well as provide customer service and support.

Additionally, where you have shown interest, we understand that you would be interested in receiving information about our products and services. Where you have said we can (i.e you gave us your clear confirmation), we would like to keep in touch with you and send you marketing messages via email about services and offers that might interest you. We will never sell your data and we promise to keep your details safe and secure. You can stop receiving marketing messages from us at any time by clicking on the ‘unsubscribe’ link in any email we send you – this way, you will always be provided with an opportunity to opt-out when you receive such information.

 

5. Personal Data sharing and disclosure

We do not, and will not, sell any of your Personal Data to any third party. It is not our business to do so – and we want to earn your trust and confidence.

However, we may share your data with companies which form part of the same group of companies that Quad Consultancy forms part of (our “Subsidiaries”), where necessary for the processing of your requests or to enhance your experience.

Additionally, we may share your Personal Data with the following categories of companies as an essential part of being able to provide our Services to you, as set out in this statement:

  • Companies that are involved in the process of getting our services from us to you, such as prospective employers and business (solely in the case of job applicants), amongst others;
  • Professional service providers, such as advertising partners, website hosts, I.T. consultants, who service us in turn to operate our business;
  • Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud; and
  • Other companies that you may approve, such as social media sites (if you choose to link your accounts to us).

In addition, there may be cases where we may disclose Personal Data because we are obliged to, as set out below:

  • to the extent that we are required to do so by law or by a competent authority;
  • in connection with any legal proceedings or prospective legal proceedings;
  • for the proper administration of justice;
  • to protect your vital interests;
  • to safeguard the integrity of the relevant website operated by us; and
  • to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling in the event of a corporate sale, merger, reorganisation, dissolution or similar event involving us and/or our Subsidiaries.

When we do share data, we do so on an understanding with the other entities that the data is to be used only for the purposes for which we originally intended.

We may also provide third parties with aggregated but anonymised information and analytics about our customers and, before we do so, we will make sure that it does not identify you. Anonymous information means it cannot lead to the identification of the Data Subjects

If we ever have to share data with entities that are outside of the EEA, we will be sure to do so in a manner that complies with the requirements established by under Applicable Legislation.

 

6. Data Subject Rights

You enjoy several rights relating to your personal information under Applicable Legislation. We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Service. Your principal rights under data protection law are:

  • the right to information;
  • the right to access;
  • the right to rectification;
  • the right to erasure;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent.

If you would like to make any requests with regards to your Personal Data held by Quad Consultancy then please contact the Principal Contact as indicated below where all queries will be dealt with in a timely manner.

Depending upon the circumstances and the request, Quad Consultancy may not be permitted to provide access to Personal Data or otherwise fully comply with your request, for example, when producing your information may reveal the identity of someone else.

 

7. Security

We take appropriate security measures to protect against loss, misuse and unauthorised access, alteration, disclosure, or destruction of your information. We take integrated steps to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and services processing Personal Data, and will restore the availability and access to information in a timely manner in the event of a physical or technical incident.

If Quad Consultancy learns of a security systems breach, we may attempt to notify you electronically   so that you can take appropriate protective steps. By using the Sites or providing Personal Data to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Sites or of our Services. We may post a notice on our website if a security breach occurs. Quad Consultancy may also send an email to you at the email address you have provided to us in these circumstances.

 

8. Data Retention

Generally, your Personal Data is kept for a period of not less than five (5) years from the end of your legal relationship with Quad Consultancy. This period may be longer in the case that legal retention requirements subsist, or where legal rights may still arise therefrom.

 

9. Cookie Policy

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

 

10. Links to other Websites

Our Website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Policy. You should exercise caution and look at the privacy policy applicable to the website in question.

 

11. Changes to this Privacy Policy

If we decide to change this Policy, we will post those changes to this Website, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we may disclose it.

We reserve the right to modify this Policy at any time. It is your obligation to review it frequently. Your continued use of this Website constitutes your agreement to this Policy and any updates.

 

12. Contacting us

If you have any questions about this Policy, or if you wish to make a complaint about how we have handled your personal information, please contact our Principal Contact Mr Mark J Galea at:

Quad Consultancy (Malta) Limited

5, Triq il-Ħuttaf, Mosta MST 4601

info@quadconsultancy.com