The Employee Privacy Notice is a mandatory document required under both EU GDPR and Maltese data protection legislation. It must be provided to all employees in Malta at the time of data collection, typically during the onboarding process or when implementing new data processing activities. The notice ensures transparency regarding how organizations handle employee personal data, covering aspects such as data collection purposes, legal bases for processing, data sharing, retention periods, and employee rights. Under Maltese law, particular attention must be paid to local requirements specified in the Data Protection Act and employment regulations. The document should be regularly reviewed and updated to reflect changes in data processing activities or regulatory requirements.
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1. Introduction: Overview of the privacy notice purpose and scope of application
2. Data Controller Details: Identity and contact details of the employer as data controller, including DPO contact if applicable
3. Categories of Personal Data: Comprehensive list of personal data types collected and processed about employees
4. Purposes of Processing: Detailed explanation of how and why employee personal data is used
5. Legal Bases for Processing: Legal grounds under GDPR for processing each category of personal data
6. Data Retention: How long different types of employee data are kept and criteria for determining retention periods
7. Data Sharing and Transfers: Information about third parties receiving employee data and any international transfers
8. Employee Rights: Explanation of GDPR rights and how employees can exercise them
9. Security Measures: Overview of measures to protect employee personal data
10. Updates to Privacy Notice: Information about how changes will be communicated
1. Automated Decision Making: Required if the employer uses automated processing or profiling affecting employees
2. CCTV and Monitoring: Include if workplace surveillance or monitoring systems are in place
3. Remote Working Data Processing: Add if employees work remotely and specific data processing occurs
4. Biometric Data Processing: Include if using biometric systems for time tracking or access control
5. Special Categories of Data: Required if processing sensitive data like health information or union membership
6. Cross-Border Data Transfers: Include if employee data is transferred outside the EU/EEA
1. Data Processing Activities Register: Detailed list of specific processing activities and their characteristics
2. Data Retention Schedule: Specific retention periods for different categories of employee data
3. Third Party Processors: List of data processors and their roles in processing employee data
4. Security Protocols: Detailed information about security measures and procedures
5. Subject Rights Request Procedure: Detailed procedure for handling employee data rights requests
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