Privacy Notice – Employees and Job Applicants
C. X. Financia Limited and its subsidiaries (“C. X. Financia”) are committed to complying with the General Data Protection Regulation and the Law providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018 (Law 125(I)/2018).
Looking after the personal information you share with us is very important, and we want you to be confident that your data is kept safely and securely and to understand how we use it.
We have published this notice to help you understand;
- What information we collect from you and why
- How we use your information and on what basis
- Who we share your information with
- How long we keep your information
- What your rights are
If we make changes to this notice we will notify you by updating it on our website at https://cxfinancia.com/privacy-notice-employees-and-job-applicants
C. X. Financia acts as ‘Data Controller’ of the personal data you provide to us, and we will sometimes refer to ourselves in this notice as “we” or “us”. By Data Controller, this means C. X. Financia determines the purposes and ways in which any personal data are, or will be, processed.
Should you need to contact us please write to:
The Data Protection Officer C. X. Financia Limited Kanika Sea Forum 28th October 353a-z, Flat 406, Limassol, 3107 Cyprus
or via [email protected] quoting “Security and Privacy Enquiry”.
This Privacy Notice was last updated on December 19th, 2019.
What information do we collect from you and why?
As your employer, we need to keep and process information about you for normal employment purposes.
The types of personal information we may collect include the following but please note this list is not exhaustive;
- Full name
- Contact information
- Date of birth
- National Insurance number and tax status information
- Payroll data and employment records
- Bank details
- Employee benefits information
- Marital status
- Ethnic origin
- Equality and diversity information
- Eligibility to work information
- Biometric data
- Next of kin/dependants details
- Sickness information
- Health data
- Criminal records
- Credit history
- CCTV monitoring, including security and performance monitoring
- Disciplinary Information
For unsuccessful job applicants, we will collect much less information about you, limited to what you provide in your CV or job application, interview notes and any tests that you undertake as part of the interview process.
You will have provided much of the information we hold but some may come from other internal sources, such as your manager, or external sources, such as referees.
We will keep and use this information in order to enable us to run the business and manage our relationship with you lawfully and appropriately during the recruitment process, whilst you are working for us, at the time when your employment ends and after you have left.
We use your information to enable us to communicate with you, process your job application, fulfil your employment contract, comply with any legal requirements, pursue our legitimate interests and protect our position in the event of legal proceedings.
How do we use your information and on what basis?
We use your information in a number of ways but again please note this list is not exhaustive;
- To assess your application form and references when you apply for a position with us
- To fulfil your contract of employment and any amendments to it
- To correspond with or about you, e.g. letters to you about a pay rise or, a letter to your mortgage company confirming your salary (at your request)
- To make sure you are paid correctly
- To offer you company benefits and to enable you to claim expenses
- To administer your participation in any share or incentive plans operated by C. X. Financia. This may include communication with you about share or incentive plan participation (e.g. Share save invitations), and collection of any tax and NICs due on any share awards (e.g. management share options)
- To be able to contact you, or your key contact, in the event of an emergency
- To record and monitor absence whether through a holiday, sickness or other absence
- For equal opportunities monitoring
- To maintain records of your career history, such as training records, appraisals and other performance measures and, where appropriate, disciplinary and grievance records
We may need to process your data to pursue our legitimate business interests, for example to prevent fraud, for administrative purposes or reporting potential crimes.
You may also be referred to in company documents and records that are produced by you and your colleagues in the course of carrying out your duties and the business of C. X. Financia.
Where necessary, we may keep information relating to your health, which could include reasons for absence, GP reports and notes. This information will be used in order to comply with our health and safety and occupational health obligations, to consider how your health affects your ability to do your job and whether any adjustments to your job might be appropriate. We will also need this data to administer and manage statutory and company sick pay.
If you leave employment and, under any share plan operated by a group company, the reason for leaving is determined to be ill-health, injury or disability, we will use the information about your physical or mental health, or disability status in reaching a decision about your entitlements under the share plan.
Where we process special categories of information relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, biometric data or sexual orientation, we do this under the legitimate interests of the Company or where it is required by law or to protect your health in an emergency.
How long we keep your information
Unsuccessful job applicants:
12 months from date of receipt of the job application
6 years from the end of the tax year in which payment was made. This could be longer should there be any Inland Revenue enquiries in progress.
Participants in C. X. Financia operated share/incentive plan schemes: 10 years from the end of the tax year in which a taxable event occurs (e.g. exercise of management share options). This could be longer should there be any Inland Revenue enquiries in progress.
Who we share your information with
We may share your information with certain third parties such as the following;
- Internally with our employees, agents and/or professional advisors. We will share this information for some of the purposes outlined in the previous section
- Contractors or third parties who provide services on our behalf which require access to your information
- Government departments where we are under a legal obligation to do so. Examples may include to fulfil our tax compliance and reporting obligations to the Inland Revenue, to prevent fraud and other criminal offences, or because of a Court Order
- External debt recovery services to pursue overpayments
- Credit Reference Agencies (for example Experian) if you have a staff credit account
In some cases, we may transfer your personal data to countries outside the European Economic Area.
Where we carry out these transfers, we will ensure that such transfers are compliant with the “General Data Protection Regulation” and the “Law providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018 (Law 125(I)/2018)“ and that appropriate measures are put in place to keep your personal information secure.
What are your rights?
You are entitled to request the following from C.X. Financia, these are called your Data Subject Rights and there is more information on these on the Commissioner for Data Protections’ website at www.dataprotection.gov.cy
- Right of access
- Right to rectification
- Right to erasure
- Right to restriction of processing
- Right to data portability
- Right to object
- Rights in regard to automated individual decision-making, including profiling
For further details on these rights and our approach to data protection generally please see the Data Protection Policy at https://cxfinancia.com/privacy-policy. If you have any questions about them, please contact our Data Protection Officer [email protected] .
If you are unhappy with the way in which C. X. Financia has handled your personal information and you have already been in contact with us (at the above details) and feel we did not resolve your issues to your satisfaction, you can contact the Cyprus Commissioner for Data Protection via his website at www.dataprotection.gov.cy.