Privacy Policy

Privacy Policy for Michael Page International (UAE) Limited, MPI(UAE)

Michael Page International (UAE) Limited, MPI(UAE)  ("we", "us" or "our") is committed to protecting the privacy of our candidates, clients and users of our website. We want to provide a safe and secure user experience. We will ensure that the information you submit to us, or which we collect, via various channels (including our website, through written correspondence (including e-mail), conversations or meetings with our consultants, or through any of our offices or websites globally), is only used for the purposes set out in this policy.

Through this Privacy Policy we aim to inform you about the types of personal data we collect from candidates, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of transparency under the DATA PROTECTION LAW DIFC LAW NO. 5 OF 2020 and national laws implementing it.

For the purpose of this Privacy Policy the controller of personal data is MPI(UAE) and our contact details are set out in the Contact section at the end of this Privacy Policy. References in this Privacy Policy to our Group of companies is to the parent company of MPI(UAE), PageGroup plc, and to other trading subsidiaries of PageGroup plc in the UAE.

The Information we collect

We will collect your personal details, including but not limited to your name and contact details (together with your e-mail address) and other relevant information from your Curriculum Vitae ("CV"). On occasion this will also include sensitive personal information such as details of criminal convictions and ethnic origin. When we receive your details and CV electronically, this may be through a direct application on one of our websites or an application that you have made through a third party job board.

We will likely obtain further personal information about you during the course of our relationship with you. This information may be obtained from you directly or from third parties, such as organisations to whom we have provided your CV and who have engaged with you as part of a job application.

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How we use your Personal Information

We will hold, use and disclose your personal information, for our legitimate business purposes including:

1. to provide our services to you;

2. to maintain our business relationship, where you are a user of our website, a client or candidate;

3. to enable you to submit your CV

for general applications, to apply for specific jobs or to subscribe to our job alerts. Please see the separate section on your CV below which outlines additional uses and disclosures;

4. to match your details with job vacancies, to assist us in finding a position that is most suitable for you and to send your personal information (including sensitive personal information) to clients in order to apply for jobs;

5. to retain your details and notify you about future job opportunities other than the specific role for which you have contacted us;

6. to answer your enquiries;

7. to direct-market products and services, advise you of news and industry updates, events, promotions and competitions, reports and other information. Before we do so, you will be given an option to opt-out of such communications and an option to unsubscribe will also be provided with each communication;

8. to fulfil contractual obligations with our clients;

9. to provide further services to you by sharing your personal information with other companies within our Group of companies as well as trusted third parties. Further details about this are set out in the separate section below on Sharing your Personal Information;

10. to release personal information to regulatory or law enforcement agencies, if we are required or permitted to do so;

11. our website uses a website recording service which can record mouse clicks, mouse movements, page scrolling and any text keyed into website forms. Data collected by this service is used to improve our website usability. The information collected is stored and is used for aggregated and statistical reporting, and is not shared with anybody else.

12. In order to provide you with personalised content on our website, with more relevant communication in our emails, and with a tailored service from our consultants, we track and record your usage and interaction with our website and emails. We employ a third party service provider to help us record, store and analyse this information to determine how we might best deliver your engagement. We ensure that no personally identifiable attributes are recorded in this database and, other than our chosen service provider, we do not share this information with any other business or affiliate.

We may process, in accordance with local regulations, certain sensitive personal data (known as special category data in DATA PROTECTION LAW DIFC LAW NO. 5 OF 2020 where you include it in information you send to us e.g. if you include information about your health, religion or ethnic origin in the CV you send to us. We may also be required to conduct a criminal records check against your details. We have processes in place to limit our use and disclosure of such sensitive data other than where permitted by law.

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The Legal Basis for Processing your Personal Information

Under DATA PROTECTION LAW DIFC LAW NO. 5 OF 2020 the main grounds that we rely upon in order to process personal information of clients and candidates are the following:

(a) Necessary for entering into, or performing, a contract – in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;

(b) Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a regulatory body or law enforcement agency;

(c) Necessary for the purposes of legitimate interests - either we, or a third party, will need to process your personal data for the purposes of our (or a third party's) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website and customer experience, informing you about our products and services and ensuring that our operations are conducted in an appropriate and efficient manner;

(d) Consent – in some circumstances, we may ask for your consent to process your personal data in a particular way.

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How we share your Personal Information

In certain circumstances we will share your personal information with other parties. Details of those parties are set out below along with the reasons for sharing it.

Other companies within our Group outside the Dubai International Financial Centre (DIFC) 

In the event you require us to explore job opportunities for you outside the EEA, we will notify you that we intend to pass your personal information to, or allow access to such information by, other companies within our Group of companies worldwide so they can use it for the purposes set out above.

A list of all the companies within our Group of companies which are outside the DIFC and their addresses can be accessed here.

If you would like details of the particular companies within our Group which can access your personal information, please contact us using the details in the Contact section below.

We apply equal rigour to the security of data held and processed across the whole of our global network. Each company within our Group of companies outside the DIFC with access to data in the Dubai International Financial Centre (DIFC) enters into a specific data protection agreement with MPI(UAE) thereby undertaking to meet the same standards of data security and to act in accordance with data protection principles applicable under the strict European data protection laws. This agreement is based on the Model Clauses as approved by the EU Commission. If you would like a copy of this agreement, please contact us using the details in the Contact section below.

Clients

We disclose your personal information to clients who have vacancies for jobs in which you are interested.

Trusted Third Parties

We will share your personal information and, where necessary, your sensitive personal information with trusted third parties where we have retained them to provide services that you or our clients have requested, such as:

• employment reference checking;
• qualification checking;
• criminal reference checking (as required);
• verification of details you have provided from third party sources; and/or
• psychometric evaluations or skills tests.

We will also share your personal information with third parties who perform functions on our behalf and provide services to us such as:

• professional advisors;
• data analytics providers;
• IT consultants carrying out testing and development work on our business technology systems;
• research and mailing houses; and/or
• function co-ordinators. We require minimum standards of confidentiality and data protection from such third parties.

To the extent that any personal information is provided to third parties outside the DIFC, or who will access the information from outside the DIFC, we will ensure that approved safeguards are in place, such as the approved standard contractual clauses.

Regulatory and Law Enforcement Agencies

As noted above, if we receive a request from a regulatory body or law enforcement agency, and if permitted under DATA PROTECTION LAW DIFC LAW NO. 5 OF 2020 and other laws, we may disclose certain personal information to such bodies or agencies.

New business owners

If we or our business merges with or is acquired by another business or company, we will share your personal information with the new owners of the business or company and their advisors. If this happens, you will be sent notice of such event.

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How long we will hold your information

The length of time we will hold or store your personal information for will depend on the services we perform for you and for how long you require these. As we often support candidates with placements over many years, and potentially throughout their careers, the purpose for which we retain candidate data is often an ongoing purpose. We conduct regular data-cleansing and updating exercises with our candidates to ensure that (a) the data that we hold is accurate and (b) we are not holding data for too long. Our standard terms of business state that our clients should retain candidate data such as CVs for the purposes of the specific role you apply for and that, as controllers of your data, they should inform you if they plan to retain your CV on file in order to notify you about potential future roles, or to otherwise hold or use your data for other purposes.

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Your rights on Information we hold about you

You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.

Right of Access

You have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the DATA PROTECTION LAW DIFC LAW NO. 5 OF 2020 permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.

Right of Rectification

If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us using any of the methods in the Contact section below.

Right of Erasure

In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.

Right to object to or restrict processing

In certain circumstances, you have the right to object to our processing of your personal information by contacting us using any of the methods in the Contact section below. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes.

You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.

Right of Data Portability

In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.

You can ask us to transmit that information to you or directly to a third party organisation.

The above right exists only in respect of personal information that:

• you have provided to us previously; and
• is processed by us using automated means.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation's systems. We are also unable to comply with requests that relate to personal information of others without their consent.

You can exercise any of the above rights by contacting us using any of the methods in the Contact section below.

Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.

You have a right to contact us via the Contact section below for more information about the safeguards we have put in place (to ensure the adequate protection of your Personal Data when this is transferred as mentioned above. You also have the right to non-discrimination when you exercise any of the above rights.

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Consent

To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the details in the Contact section below.

Job Alerts

To subscribe to job alerts emails, you will be required to provide your name and e-mail address, which will be used for the purpose of keeping you informed, by e-mail, of the latest jobs in your nominated industry and to provide you with industry news and other information related to our services.

Should you decide that you no longer wish to receive this information, unsubscribe links are provided in every job alert email that you receive.

Job alerts emails are sent by MPI(UAE) or a company within our Group of companies. Where the sender is based outside the EEA your details will be sent to or accessed by that entity to enable them to issue the relevant job e-mail alert to you.

See details of all the companies within our Group of companies.

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Curriculum Vitae

We give you the option of submitting your CV via our website or by providing your CV to one of our consultants. You can do this either to apply for a specific advertised job or for consideration by our recruitment consultants for positions as they come up. Your CV will be stored in our database, and will be accessible by our recruitment consultants.

Your CV may also be emailed directly to other companies within our Group of companies for review and entry onto their database to enable them to provide their services to you. You are able to withdraw your permission for your data being processed outside the DIFC upon completing your registration form with us.

You can update your CV at any time, simply by following the same procedure to submit a new CV. Your old CV will automatically be archived providing the submission details remain the same (for example you submit both CVs using the same email address or you advise the relevant contact of your new submission).

Contact us

If you have any enquires or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, you can contact our Data Protection Officer via:

Using this form: https://www.michaelpage.ae/difc-request
Or sending an email to DIFCprocessing@michaelpage.ae
Or sending a letter to the following postal address:

No. 202 Al Fattan Currency House
Tower 1, Dubai International Finance Centre (DIFC)
PO Box 506702
Dubai
United Arab Emirates

Contact the Commissioner

You have the right to make a complaint at any time to the relevant authority that safeguards your interests. The details of the DIFC Data Protection Commissioner are provided below:

DIFC Data Protection Commissioner
DIFC Authority
Level 14, The Gate Building
+971 4 362 2222
commissioner@dp.difc.ae

Changes to this privacy notice

We reserve the right to update this privacy notice at any time. We will publish the most updated privacy notice on our website. We may also notify you in other ways from time to time about the processing of your personal information where we process your data outside of the published privacy notice.

Last updated: January 2023