24th May 2018
Malta Union of Teachers – Policy on the processing of personal data
1. Purpose for processing of personal data
1.1 In the conduct of our professional services we may need to collect and use personal data about you, which we will hold and process as data controllers or data processor under the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the “General Data Protection Regulation” or “GDPR”).
1.2 All terms used in this section shall have the same meaning as in the GDPR.
1.3 All such personal information will be held and processed strictly in accordance with the provisions of the GDPR.
1.4 Personal data will be collected and processed for the purposes strictly connected to the conduct of the services offered. Personal data will also be processed for the purpose of compliance with applicable laws, legislation, regulations, rules and any other applicable rules to which MUT is subject.
1.5 Where the processing of personal data for a purpose other than the purposes indicated in this section, MUT shall, in order to ascertain whether processing for another purpose is compatible with the purpose for which the personal data is initially collected, take into account, inter alia:
a. Any link between the purposes for which the personal data has been collected and the purposes of the intended further processing;
b. The context in which the personal data has been collected;
c. The nature of the personal data;
d. The possible consequences of the intended further processing for the member;
e. The existence of appropriate safeguards, which may include encryption or pseudonymisation. MUT shall provide the member, prior to the further processing for purposes other than the ones stipulated, with information on that other purpose and any other relevant information beforehand.
2. Quality of personal data and the right to rectification and erasure
2.1 Personal data shall be accurate and where necessary kept up to date. MUT shall take any reasonable steps to ensure that personal data that is inaccurate is erased or rectified without delay.
2.2 For the purposes indicated in Clause 2.1 above, the member shall provide MUT with any information or documentation in order for MUT to comply with such obligation.
2.3 Natural persons have the right to obtain by MUT the rectification of inaccurate data concerning him or her. Such request can be made by logging in to the MUT website, in the ‘Member Personal Details’ page under ‘Member’s Area’, or by sending an email in writing to the following email address: email@example.com.
2.4 Natural persons have the right to obtain by MUT the erasure of personal data if the personal data is no longer necessary in relation to the purpose for which it was collected, the data subject withdraws consent and personal data has been unlawfully processed. MUT shall give specific reasons in case it takes the decision of not erasing such data. The request for erasure of personal data is to be sent in writing to the following email address: firstname.lastname@example.org.
3. Right of access
3.1 All individuals have a right under the GDPR to obtain details of information held on them by the firm. If you wish to exercise this right you can log in to the MUT website, in the ‘Member Personal Details’ page under ‘Member’s Area’, or forward your request in writing to the following email address: email@example.com.
4. Transferring of personal data
4.1 We will not, without consent, transfer personal data to any third party except where such transfer is a necessary part of the services provided (e.g. transfer of information to third parties authorised under the applicable legislation (such as the Directorate of Employment and Industrial Relations)), or where we are required to do so by operation of law.
4.2 We may provide personal information to our professional advisers and specialist consultants and others where required by law including regulators.
5. Data retention
5.1 The personal data will be kept in a form which permits identification of individuals for no longer than is necessary for the purposes of the services of MUT.
6. Events of breach
6.1 Each individual has the right to lodge a complaint against any data breach by communicating such breach to the Information and Data Protection Commissioner by filling in the complaint form available HERE.
7. Legitimate communications and withdrawal of consent
7.1 The MUT sends regular communications, including but not limited to eNewsletters, to members to update them about Union activities including bargaining updates and outcomes, elections, meetings, campaigns, rule changes, training, services and important developments in the education sector. This is essential and a legitimate activity of the trade union and, as confirmed with the EU Commission through communication with the ETUC and advice by specialized lawyers in the field, MUT members have a legitimate expectation to be kept up-to-date with the union’s activities and the MUT has a legitimate interest in ensuring that members are aware of what is happening in their own union.
7.2 If you do not wish to continue receiving the eNewsletter kindly click HERE. You can withdraw your permission to receive our eNewsletter at any time by using the unsubscribe link found at the bottom of every eNewsletter or by sending an email to firstname.lastname@example.org. You can also unsubscribe by logging in to the website, where apart from unsubscribing you can also see your personal data and if need be update it. Such withdrawal of consent will be without prejudice to processing of your personal data for the legitimate purposes indicated above and for your status as a member of the MUT. For the avoidance of any doubt, withdrawal of consent from communications will not constitute formal resignation from the Union.