Employee Privacy Policy Al Amthal Group and its affiliated companies (Al-Amthal)
Introduction
Al-Amthal respects the privacy of the personal information of the individuals with whom we interact. If you are a current or former Al-Amthal employee, or a job applicant, this Privacy Policy describes the personal information that Al-Amthal collects from or about you, and how we use and to whom we disclose that information.
This Privacy Policy applies only to the personal information of all individuals who seek to be, are, or were employed by Al-Amthal (collectively, an "employee"). If you submit a job application through our website, you agree to our Employee Privacy Policy.
Organizations Covered by this Policy
Al-Amthal is a group of companies with operations both inside and outside of the Kingdom of Bahrain.
The Al Amthal Group Company W.L.L. (“Al-Amthal”) includes the parent company, Al-Amthal for Consultancy and Software and its affiliated entities (W.L.L. companies), including ECnet, Mallats Global Solutions, Ella Real Estate Solutions (Aqaraats), NC Link, Power Water Distillation Equipment Co. and Tasleeh for Maintenance and Cleaning Services.
All references in this Privacy Policy to "Al-Amthal", "we", "us", "our" and like terms refer collectively to the Al-Amthal Group.
Policy of Compliance
Al-Amthal endeavors to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual's right to privacy are different from one jurisdiction to another. This Privacy Policy was developed to guide the activities of the Al-Amthal Group as a whole. In addition to the practices set forth in this Privacy Policy, Al-Amthal or certain members of the Al-Amthal Groupp may adopt specific information handling and privacy practices to address privacy issues unique to their operations and jurisdictional requirements. If you are unsure if or how this Privacy Policy applies to you, please contact our office for more information.
What is Personal Information?
For the purposes of this Privacy Policy, personal information is any information about an identified or identifiable individual. Personal information does not include anonymous or non-personal information (i.e. information that cannot be associated with or tracked back to a specific individual).
What Personal Information Do We Collect?
We collect and maintain different types of personal information in respect of those individuals who seek to be, are, or were employed by us. This includes personal information contained in:
resumes and/or applications;
references and interview notes;
photographs and video;
letters of offer and acceptance of employment;
mandatory policy acknowledgement sign-off sheets;
payroll information; including but not limited to social insurance number, pay cheque deposit information, and LMRA/SIO information;
wage and benefit information;
beneficiary and emergency contact information;
background screening information; and
medical checks results.
In addition to the examples listed above, personal information also includes information such as name, home address, telephone, personal email address, date of birth, employee identification number and marital status, and any other information necessary to Al-Amthal's business purposes, which is voluntarily disclosed in the course of an employee's application for and employment with Al-Amthal. Personal information collected for employment purposes is considered “employment data.”
As a general rule, Al-Amthal collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).
From time to time, we may utilize the services of third parties (including other members of the Al-Amthal Group) in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
How Do We Use Personal Information?
Employment data is used and disclosed for our business purposes, including establishing, managing or terminating your employment relationship with Al-Amthal. Such uses include:
determining eligibility for initial employment, including the verification of references and qualifications;
administering pay and benefits;
processing employee work-related claims (e.g. worker compensation, insurance claims, etc.)
establishing training and/or development requirements;
conducting performance reviews and determining performance requirements;
assessing qualifications for a particular job or task;
gathering evidence for disciplinary action, or termination;
establishing a contact point in the event of an emergency (such as next of kin);
complying with applicable labor or employment statutes;
compiling directories;
ensuring the security of company-held information;
such other purposes as are reasonably required by Al-Amthal in connection with your employment; and
for any additional purposes that we advise you of and for which we have a legal basis, which may for instance be your consent when such consent is required by law.
We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
Monitoring
The work output of Al-Amthal's employees, whether in paper record, computer files, or in any other storage format belongs to us, and that work output, and the tools used to generate that work output, are always subject to review and monitoring by Al-Amthal.
In the course of conducting our business, we may monitor employee activities and our premises and property. For example, the entrance of our Bahrain HQ is equipped with a surveillance camera, installed and controlled by the building management for the protection of tenants, their employees and third parties, and to protect against theft, vandalism and damage to the tenant’s property.
Pursuant to our Acceptable Use of Computer Systems, Equipment, Infrastructure and Internet Systems Policy, we have the capability to monitor all employees' computer and e-mail use.
This is not to suggest that all employees will in fact be monitored or their actions subject to constant surveillance. It is meant to bring to your attention that such monitoring may occur and may result in the collection of personal information from employees (e.g. through their use of our resources). When using Al-Amthal equipment or resources employees should not have any expectation of privacy with respect to their use of such equipment or resources.
When Do We Disclose Your Personal Information?
We may share your personal information with our employees, contractors, consultants and other parties (including other members of the Al-Amthal Group) who require such information to assist us with establishing, managing or terminating our employment relationship with you, including: parties that provide products or services to us or on our behalf and parties that collaborate with us in the provision of products or services to you. In some instances, such parties may also provide certain information technology and data processing services to us so that we may operate our business. We may share personal information with such parties both in and outside of your home jurisdiction, and as result, your personal information may be collected, used, processed, stored or disclosed in Bahrain or in our regional offices. Personal information is only transferred by us to another country, including within the Al-Amthal Group, if this is required or permitted under the applicable privacy legislation.
When we share personal information with such parties we typically require that they only use or disclose such personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy.
In addition, personal information may be disclosed or transferred to another party (including to another member of the Al-Amthal Group outside of your home jurisdiction) in the event of a change in ownership of, or a grant of a security interest in, all or a part of Al-Amthal through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.
Further, your personal information may be disclosed:
as permitted or required by applicable law or regulatory requirements. In such a case, we will endeavor to not disclose more personal information than is required under the circumstances;
to comply with valid legal processes such as search warrants, subpoenas or court orders;
as part of Al-Amthal's regular reporting activities to other members of the Al-Amthal Family (including outside of your home jurisdiction);
to protect the rights and property of Al-Amthal;
during emergency situations or where necessary to protect the safety of a person or group of persons;
where the personal information is publicly available; or
with your consent where such consent is required by law.
We do not sell personal information subject to this privacy policy to third parties.
Notification and Consent
Privacy laws do not generally require Al-Amthal to obtain your consent for the collection, use or disclosure of personal information for the purpose of establishing, managing or terminating your employment relationship. In addition, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
To the extent that your consent is required, we will assume, unless you advise us otherwise, that you have consented to Al-Amthal collecting, using and disclosing your personal information for the purposes stated above (including any other purposes stated or reasonably implied at the time such personal information was provided to us).
Where your consent was required for our collection, use or disclosure of your personal information, you may, at any time, subject to legal or contractual restrictions and reasonable notice, withdraw your consent. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to the HR/Admin Department.
How is Your Personal Information Protected?
Al-Amthal endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorized access, copying, use, modification or disclosure.
Despite these safeguards, no method of transmission over the Internet or data storage is fully secure. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
How Long is Your Personal Information Retained?
Except as otherwise permitted or required by applicable law or regulatory requirements, Al-Amthal endeavors to retain your personal information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations). We may, instead of destroying or erasing your personal information, make it accessible only for statistical and HR or administrational requirements by HR/Admin personnel only.
Updating Your Personal Information
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of your employment, please update your HRMS Employee File and/or keep us informed of such changes.
In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
Access to Your Personal Information and Deletion of Your Personal Information
You can request access to, and rectification or deletion of personal information that we hold about you, which is not accessible to you via our HRMS.
To make such a request, please contact the HR/Admin Department. Please note that any such communication must be in writing. In your request, please make clear what specific personal information you would like to have accessed, rectified, or deleted.
When requesting access to, or rectification or deletion of your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, rectify or delete, as well as to search for and provide you with the personal information that we hold about you. If you require assistance in preparing your request, please contact the HR/Admin Department.
Your right to access, rectify, or delete the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse your request. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
In the event that we cannot provide you with access to, or rectification or deletion of your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
We will not discriminate against you for exercising any of your rights described in this Privacy Policy.
Inquiries or Concerns?
If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact the HR/Admin Department by telephone, in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are unsatisfied with our response, you may be entitled to make a written submission to the supervisory authority applicable for your jurisdiction.
Privacy Compliance
The HR/Admin Department and its staff are responsible to oversee compliance with this Privacy Policy. The contact information for our HR/Admin Department is as follows:
HR/Admin Email: hr@al-amthal.com
Head of Department: Beate (Zahra) Schoek-Awachi
HoD Email: zawachi@al-amthal.com
Mobile: +973 39294442
Revisions to this Privacy Policy
Al-Amthal may from time to time make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will communicate any revised version of this Privacy Policy. Any changes to this Privacy Policy will be effective from the time they are communicated, provided that any change that relates to why we collect, use or disclose your personal information will not apply to you, where your consent is required to such collection, use or disclosure, until we have obtained your consent to such change. This Privacy Policy was last reviewed as of the Effective Date set forth below.
Interpretation of this Privacy Policy
Any interpretation associated with this Privacy Policy will be made by Al-Amthal ISO Management Representative. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word 'including' is used, it shall mean 'including without limitation.
This Privacy Policy does not create or confer upon any individual any rights, or impose upon Al-Amthal any rights or obligations outside of, or in addition to, any rights or obligations imposed by the privacy laws applicable to such individual's personal information. Should there be, in a specific case, any inconsistency between this Privacy Policy and such privacy laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.
Effective Date
29th May 2022