Privacy Policy
1. Introduction
The Malta Trust Foundation (“the Foundation”/ “we”/ “our”/ “us”) is committed to protecting and respecting your privacy. We are pleased to provide you with our privacy notice and request you to read it carefully.
We have created this privacy notice to explain to you:
- how we use any personal data that we receive from you or may collect about you, and
- your privacy rights under applicable privacy laws.
Our use of your personal data is subject to your instructions, the EU General Data Protection Regulation (“GDPR”), other relevant Maltese and EU legislation and our professional duty of confidentiality.
For the purposes of the GDPR, the Data Controller is:
The Malta Trust Foundation– Maison Notre Dame, St Calcedonius Square, Floriana, FRN 1530, Malta.
Responsible person for data protection matters: Julia Spiteri
If you wish to request any clarification or additional information in relation to this privacy notice, or you may wish to exercise any of your rights in relation to your personal data, please send us an email on
privacy@maltatrustfoundation.org or call us on +356221142
In the event that we modify this privacy notice, we will immediately inform you
2. Key terms
| Data Controller | The person that determines the purposes and means of the processing of personal data. |
| Personal data | Personal Data is information that could identify you. It could be anything like an email address, photo, C.V. and information relating to your health. |
| Processing | Any operation which is performed on personal data such as collection, storage, use and erasure. |
| Sensitive Personal Data | Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic and biometric data, and data concerning health, sex life or sexual orientation. |
3. Personal Data that we collect, may process and what we may use it for
Most of the information we collect and process is given to us directly by you. This includes information that you provide us with over the telephone, email or any other medium. This includes all personal information that you have provided us with when you submitted an application to participate in and/or in relation to one or more of our projects as well as any other additional information and documentation you submitted to us in relation to the application and/or participation in a project, or when you otherwise contacted us through our website or email. This data can include your contact details, your health information, and information about your requirements. Information about your health is considered to be a ‘special category’ of personal data under data protection law which requires that we satisfy additional conditions if we process such sensitive personal data.
We may also collect personal data about you through our CCTV surveillance system “the CCTV system” which we have installed outside and/or within our premises at Maison Notre Dame, St Calcedonius Square, Floriana, FRN 1530, Malta and/or at the sites from where we operate our projects. Signs are placed outside our premises to inform you that CCTV is in operation. The CCTV system is capable of being monitored for 24 hours every day of the year. All images captured by the CCTV System remain the property of The Malta Trust Foundation.
| Activity | Personal data we may process | For what reasons we may use your personal data | Our legal bases |
| Submitting the ‘contact us’ form on our website | Name and Surname Email Address Residential Address | This information is necessary for us to forward our replies to you. | Consent You are providing us with your consent to process your personal data upon the submission of your personal data on the ‘contact us’ online form. Pursuing legitimate interests: Responding to your communications with us Getting to know the relative contact person who could include a potential applicant or volunteer for one of our projects |
|
Referrals Meetings with you Communicating with us through calls or emails |
If you are referred to us, Information that is provided to us by our social partners, or if you come directly to us, information that is provided by you. These include: · full name · address · ID card number · Mobile/Phone number · Qualifications · Work Experience · Criminal conduct information Sensitive data such as data concerning your health. |
To provide you with our services. |
Consent You provide us with your consent to process your data for one of our projects
For our legitimate interests: Getting to know you to be able to help you through our projects.
Responding to your communications with us. |
| Applying to participate in one of our projects or other activities |
All the requested details you provided us in the application form which include:
The information requested will vary depending on the project, but we may ask for:
Other information or documentation which we may collect about you and/or which may be in the public domain. |
To identify and assess your suitability to benefit from the project. Maintaining records of applicants and participants. To communicate with you by any effective means including communications by email, phone, and post. To be aware of any special needs you may have, or whether you require specific attention. Other purposes such as carrying out statistical analysis. | Pursuing legitimate interests : To assess which applicants are most adequately suited to benefit from our projects. In so far as the information includes special categories of data (health data), we process this on the basis that it is necessary for the provision of health or social care. Performance of a contract with you To provide you with the service you have applied for. Consent You are consenting to us processing your personal data upon the submission of your personal data in the context of your application, which would include conducting necessary checks to satisfy our legitimate interests. |
| Contacting us through email or telephone | Any personal details, including your name, surname, email address or telephone number, depending on whether you contacted us by email or by calling. Any additional information which you choose to provide us with it. | To identify the person contacting us, and to store such person’s details in order to reply to any queries or provide any requested assistance. | Pursuing legitimate interests: To be able to identify any persons contacting us, to better understand our current reach, and help you suitably. Consent By providing us with your personal details to contact us you are consenting to providing us such information. |
| CCTV System | Images captured by CCTV cameras which are installed outside/inside our premises or at the sites from where our projects are carried out. | Used for security and monitoring purposes of our visitors and employees | Pursuing legitimate interests : Keeping our visitors and employees safe and secure by preventing crime, preventing employee misconduct and, ensuring compliance with health and safety procedures. |
We are committed to protecting your personal data, whether it is sensitive or not ad we only process data if we need to for a specific purpose. The table below sets out the types of personal data that we may process, for what we may use it and our legal bases, which are our reasons for processing:
4. Use of cookies
We use cookies to optimise the functionality of our website. A cookie is a small file that contains certain data such as the site’s name and unique user ID and is downloaded to and stored on your device when you visit a website. Cookies are generally used to make websites work more efficiently and enable website owners to gather information about the use of their website. Thus, they may be used for different purposes such as website analytics, targeted advertising, counting visitors, and monitoring their behaviour.
Most, but not all, of the cookies we use are automatically deleted from your computer when you leave our website or shortly afterwards.
For information about how we use cookies on our websites, please see our Cookie Policy at https://www.maltatrustfoundation.org/cookie-policy/
5. With whom we share your data
We may share your personal data internally with the relevant staff at the Malta Trust Foundation. We may, on occasion, share personal data with third parties. These can be contractors acting on our behalf, or separate data controllers in which case we will only share the data if we are permitted to do so by law. We may share your data with the following persons:
- service providers – we may disclose your personal data to third party service providers that provide us with services. These include but not limited to our collaborators on specific projects, professionals mainly in the psychosocial and health sector, civil society organisations as well as other services providers such cloud storage providers and website hosting providers consultants.
- other third parties – where necessary and to carry out your instructions.
We may also disclose your personal data in response to any requests made from law enforcement agencies, government entities or public authorities, to comply with court orders, to obtain legal remedies and/or limit our damages, to protect your rights as well as our rights and the rights of our employees and where we deem necessary or appropriate under applicable laws and regulations.
6. Where your personal data is held
We hold your personal data at our offices and those of our third-party service providers as described in clause 4 above. Some of these service providers may be located outside the European Economic Area (EEA). Any such transfers will be processed in accordance with specific EU and Maltese data protection laws as also provided in clause 6 below.
7. Transfers of your personal data outside the EEA
We endeavour to only store personal data in and transfer it to jurisdictions where it will afforded an adequate level of protection or when we are able to provide appropriate safeguards and ensure that your rights as a data subject can be enforced.
Transfers of personal data outside the EEA are subject to specific EU and Maltese data protection laws.
8. Personal Data retention period
We will retain your personal data even after the completion of our services to you. We will need to keep your personal data after we have provided you with our services in order to comply with our record keeping requirements in terms of the law and to be able to respond to any questions, complaints or claims made by you.
We will not collect more data than we require or retain your data for longer than necessary to fulfil the purposes outlined in this notice.
9. Your rights with respect to your Personal Data
You have the following rights if you reside in the EU:
| Right of Access |
| The right to access and be provided with a copy of your personal data. |
| Right to Rectification |
| The right to require us to correct any inaccurate personal data about you. |
| Right to be forgotten |
| The right to require us to delete your personal data in certain circumstances. |
| Right to restriction of processing |
| The right to require us to restrict processing your personal data in certain circumstances. |
| Right to data portability |
| The right to receive your personal data which you provided to us, in a structured, commonly used and machine-readable format and the right to transmit that data to another data controller in certain circumstances. |
| Right to object |
| The right to object to the processing of your personal data in certain circumstances which include continued processing of your data carried out for the purpose of our legitimate interests. |
| Right not to be subject to automated processing |
| The right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or significantly affects you. |
Should you require any further information on each of the above rights or would like to exercise any of them, please contact us on privacy@maltatrustfoundation.org
10. Protecting your personal data
We have implemented security measures to protect your personal data that we collect from being used or accessed unlawfully or accidentally lost. We only grant access to your personal data to those persons who have a genuine need to access it. Those processing your personal data are subject to the duty of confidentiality.
11. Complaints
We would like to resolve any concern that you may have about the processing of your personal data directly with you. However, you have the right to lodge a complaint with a supervisory authority, in the EU state in which you work, reside or where the alleged infringement of data protection laws took place. The supervisory authority in Malta is the Office of the Information and Data Protection Commissioner which may be contacted at
https://idpc.org.mt/en/Pages/contact/complaints.aspx
Last updated on 14th Nov 2023