1. Scope
All data subjects whose personal data is collected, in line with the requirements of the GDPR.
2. Responsibilities
2.1. The CIO is responsible for ensuring that this notice is made available to data subjects prior to Centrecom collecting/processing their personal data.
2.2. All employees/staff of Centrecom who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured if applicable.
3. Privacy notice
Centrecom acts as a processor when collecting personal data, thus Centrecom provides information within this Privacy Notice regarding how and why the data is used and the rights that Centrecom has over those personal data.
Our Data Protection Officer and data protection representatives can be contacted directly here: dpo@centrecom.eu
The personal data we collect, and the process is as follows:
- Name and surname
- ID card number
- Address
- Date of birth
- Account number
- Vehicle registration number
- Personal email address
- Contact number
- Credit card details
- Passport number
- PNR
- IBAN number
- Tax number
- VAT number
- NI number
- Cheque number
Source of personal data is:
- Systems, provided by the relative clients, who act as Controllers.
Our lawful basis for processing for the personal data is:
- Contractual obligations.
The personal data we collect will be used for the following purpose:
· Render services on behalf of the Controller.
In addition to the above, we also collect name & surname, contact number and contact email direct from you, the Data Subject, as marketing leads through personal engagements, conferences and networking to facilitate our legitimate interests for business-related purposes.
3.1 Disclosure outside EU/ International organisations
Centrecom will not pass on your personal data to the third parties outside Malta, unless agreed to do so in writing between the Controller and Processor.
3.2 Retention Period
Various categories of personal data are retained according to the applicable legislation and requirements. For further detail please submit request to Centrecom via email to dpo@centrecom.eu
3.3 Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: if Centrecom refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause “Complaints” below.
All the above requests will be forwarded on should there be a third party outside-EU and/or international organisations, (as stated in “Disclosure outside EU / International organisations” above) or local contracted entity and/or individual, who are involved in the in the processing of your personal data.
3.4 Complaints
If you wish to make a complaint about how your personal data is being processed by Centrecom (or third parties as described in part “Disclosure outside EU/ International organisations” above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Centrecom data protection representatives Data Protection Officer.
The details for each of these contacts are:
| Supervisory Authority | Data Protection Officer | |
| Organisation Name: | IDPC | Centrecom Ltd. |
| Contact Name: | Saviour Cachia | Stefan Ancilleri |
| Address line 1: | Airways House | Unit F11 |
| Address line 2: | Second Floor | Level 2 |
| Address line 3: | High Street | Mosta Technopark |
| Address line 4: | Sliema | Mosta |
| Address line 5: | SLM 1549 | MST 3000 |
| Address line 6: | Malta | Malta |
| Email: | saviour.v.cachia@idpc.org.mt | dpo@centrecom.eu |
| Telephone: | (+356) 2328 7100 | (+356) 2364 4058 |
3.5. Privacy statement
More information about how and why we process your personal data can be found in the below statements.
Personal data
Under the EU’s General Data Protection Regulation (GDPR) personal data is identified as:
“Any information relating to an identified or identifiable natural person (‘data subject’); 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.”
How we use your information
This privacy notice tells you how we, Centrecom, will collect and use your personal data within the lawful basis of processing of such data.
Why does Centrecom need to collect and store personal data?
For us to provide you with a service we need to collect personal data for correspondence purposes and/or detailed service provision. In any event, we are committed to ensuring that the information we collect, and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
In terms of being contacted for marketing purposes Centrecom would contact you for additional consent.
Will Centrecom share my personal data with anyone else?
We may pass your personal data on to third-party service providers contracted to Centrecom while dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Centrecom procedures. If we wish to pass your sensitive personal data onto a third party, which is not located in Malta or to the local third party, other than the authority, we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
How will Centrecom use the personal data it collects about me?
Centrecom will process (collect, store and use) the information you provide in a manager compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Centrecom is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will Centrecom contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Can I find out the personal data that the organisation holds about me?
Centrecom at your request, can confirm what information we hold about you and how it is processed. If Centrecom does hold personal data about you, you can request the following information:
- Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of Centrecom or a third party, information about those interests.
- The categories of personal data collected, stored, and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data,
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to access this?
Centrecom accepts your National ID Card, as verification of your identity, when information on your personal data is requested.
Data Subject Request Policy
1. Scope
All personal data processed by Centrecom is within the scope of this procedure.
Data subjects are entitled to obtain:
- Confirmation as to whether Centrecom is processing any personal data about that individual.
- Access to their personal data.
- Any related information.
- The logic involved in any automated decisions in relation to the data subject.
2. Data subject request policy
2.1 General points
- Information that is provided to any data subject should be clear, understandable, transparent, and easily accessible.
- The language used for any information should be plain and clear.
- The organisation should be able to act on any request of the data subject, unless it is impossible to establish the data subject’s identity.
- The request of the data subject should be completed within one month.
- If the request is highly complex, the response time might be extended for another two months, however, Centrecom should inform the data subject for the delay within one month and give relevant reasons.
- In cases where the request is in electronic form, the response should also be in the same form, unless it is otherwise requested by the data subject.
- The response required by the data subjects should be made free of charge, unless the request is “manifestly unfounded or excessive.” In such a case, the organisation either charges a fee or refuses the request.
It is the right of the data subject to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
2.4 The Right to be Informed and the Right of Access
The data subject has the right to be informed about the collection and use of the data. This is applicable for cases when data is collected directly from the data subject or obtained from another source. There is a specific document, namely, the Privacy Notice Procedure, which provides detailed information for complying with this requirement of the GDPR.
It is the right of the data subject to know whether Centrecom process data about them and ask for access to that data.
Additionally, the data subject has the right to the following information:
- The categories of the data subject’s personal data.
- The purpose of processing personal data.
- The rights of the data subject to restrict or erase their personal data.
- The categories of the recipients of the data, specifically when is the case of any international organisation or third party
2.5 The Right to be Forgotten and the Right to Rectification
It is the right of the data subject to require Centrecom to erase the data related to them if one of the few listed cases applies:
- There are no legal grounds for processing the personal data due to the withdrawal of consent from the data subject.
- The data subject’s personal data are not necessary for the purpose that they were collected.
- There has been an unlawful processing of personal data.
- Compliance reasons are involved.
- The personal data of the data subject was relevant when the data subject was a child.
On the other hand, the right to rectification applies when the data is inaccurate or incomplete. It is the right of the data subject to request that the personal data be corrected or completed if they are incomplete.
Centrecom must validate the information from the data subject to make sure that the information is accurate before amending it.
2.6 The Right of Process Restriction
It is the right of the data subject to restrict the process if one of the following occurs:
- If the data subject questions the accuracy of the data until the accuracy of the data is verified.
- If the process is unlawful.
- If a decision on an objection to processing is pending.
For Centrecom to handle these requests, the involvement of Centrecom DPO is needed and in more critical cases the involvement of the top management.
2.7 The Right to Object and to Data Portability
It is the right of the data subject to object the processing of data if:
- Performing a specific task which is performed in the public interest.
- For purposes of the legitimate interests of the controller.
In cases where the objection has taken place, Centrecom should be able to justify the actions taken and suspend the processing. However, in cases where the personal data is used for marketing purposes, there is no other choice; the data can no longer be processed.
Based on the Article 20 of the GDPR, data subject has the right of requesting their personal data in a specific way such as a “structured, commonly used and machine-readable format” and transfer that data to another party. This is the case when the processing of personal data is based on the data subject’s consent and the processing was done automatically.
2.8. Automated Decision-making and Profiling Rights
The data subject has the right to require human intervention and not be the subject to automated decision-making, specifically, when the decision has a major impact on the data subject. However, there are some exceptions regarding this right, such as:
- If the decision is authorised by law.
- If the decision is necessary for a contract.
- If the decision is based on the data subject’s explicit consent.
If these cases apply or not, a judgment should be made from Centrecom to validate these exceptions.
CC-ITDPO-005 - Data Subject Request Form
CC-ITDPO-009 - Data Subject Consent Withdrawal Form