1. Muskita Hotels LTD owner and operator of Four Seasons Hotel, Cyprus (“we”, “us”) is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. This notice applies to current and former employees, workers and contractors. This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time in accordance with the General Data Protection Regulation (GDPR) and any other applicable data protection laws and regulations (“Data Protection Laws”).
2. Data protection principles
We will comply with Data Protection Laws. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
3. The kind of information we hold about you
We will collect, store, and use the following categories of personal information about you: Personal contact details such as name, title, signature, addresses, telephone numbers, emergency contact number, personal email addresses, age, whether you are EU citizen or not, Alien Registration Certificate for non-EU citizens, education specifics or if you are still studying such as name of school/university, degree or certificate, major of study, graduation date, spoken languages level, previous employment record information such as name of employer , dates, position and description of duties, Date of birth, social insurance number, IBAN number and bank account details, payroll records, salary and provident fund details, CCTV footage, videos or photos of active employees who have consented to the processing, accommodation details only for those whose accommodation is provided and handled by us and other information obtained through electronic means such as swipe card records, Information about your use of our information and communications systems, Copy of Passport, ID or some other form of identification. We may also collect, store and use the following “special categories” of more sensitive personal information: Information about your marital status, information and number of dependents, health, including any medical condition, health and sickness records including daily temperature of incoming employees, your gender, medical examinations for food handlers, Medical condition results for third country nationals, incidents for Reward and Recognition purposes (Staff Bravo), training records, union membership. Information about your race or ethnicity, Information about your health, including any medical condition, health and sickness records, Information about criminal convictions and offences, Personal opinions about job related issues or supervisors / managers, such as views about our organization, your age, managerial level or length of service (annual staff opinion survey, IIP)
4. How is your personal information collected?
We collect personal information about employees, workers and contractors through the application and recruitment process, either directly from candidates or sometimes from an employment agency or background check provider. We may sometimes collect additional information from third parties including former employers, credit reference agencies or other background check agencies (i.e. from chemists, for example Medical Tests for Food Handlers, training evaluation for external partners / training companies)
We will collect additional personal information in the course of job-related activities throughout the period you are working for us.
5. How we will use information about you
Making a decision about your recruitment or appointment, Determining the terms on which you work for us, Checking if you are legally entitled to work in Cyprus, Paying you and, if you are an employee, deducting tax and National Insurance contributions, Providing the following benefits to you: Maternity leave, Sick Leave, Accidents Leave, Provident fund employer’s contribution and Provident Fund Employee Contribution, Welfare Fund approved benefits such as marriage benefit, birth of child benefit, Liaising with your pension provider, Administering the contract we have entered into with you, Business management and planning, including accounting and auditing, Conducting performance reviews, managing performance and determining performance requirements, Making decisions about salary reviews and compensation, Assessing qualifications for a particular job or task, including decisions about promotions, Gathering evidence for possible grievance or disciplinary hearings, Making decisions about your continued employment or engagement, Making arrangements for the termination of our working relationship, Education, training and development requirements, Dealing with legal disputes involving you, or other employees, workers and contractors, including accidents at work, Ascertaining your fitness to work, Managing sickness absence, Complying with health and safety obligations, To prevent fraud, To monitor your use of our information and communication systems to ensure compliance with our Information Technology policies, To ensure network and information security, including preventing unauthorized access to our computer and electronic communications systems and preventing malicious software distribution, To conduct data analytics studies to review and better understand employee retention and attrition rates (Equal opportunities monitoring) Monitor your health by taking daily temperature as an indication of symptoms of a Covid-19 case
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
6. If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you (such as paying you or providing a benefit), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).
7. Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
8. How we use particularly sensitive personal information
We will use information relating to leaves of absence, which may include sickness absence or family related leaves, including taking the daily temperature of incoming employees to comply with employment and other applicable laws. We will use information about your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits. We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting. We will use trade union membership information to pay trade union premiums, register the status of a protected employee and to comply with employment law obligations.
We will use your information in the framework of internal communication policies such as the printing of leaflets regarding the hotel, training and development, publications such as the Staff Newsletter, the Welfare Fund Activity Report (Έκθεση Πεπραγμένων Ταμείου Ευημερίας), or for external publications/external branding (videos with staff telling their stories – used both internally and externally to trusted third-party websites and websites operated by Muskita Hotels LTD) to promote our staff culture, schools, universities, printing materials with activities in the hotel areas and photos of staff, only when you have been informed explicitly on the purpose and you have consented to your depiction.
9. Do we need your consent?
We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific rights in the field of employment law. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your contract with us that you agree to any request for consent from us.
10. INFORMATION ABOUT CRIMINAL CONVICTIONS For certain employees (i.e. Security Department and Non-EU Nationals) we envisage that we will require information about criminal convictions. We will only collect information about criminal convictions if it is appropriate, given the nature of the role/position, and where we are legally able/obliged to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process or we may be notified of such information directly by you in the course of you working for us. We will use information about criminal convictions and offences in the following ways: For Security Personnel (Φύλακες Ασφαλείας), as required for the completion of the relevant certification for the production of license (by police) of “private security officer”, For third-country nationals needed by immigration authorities for the application of Visa for the purposes of employment, Statement in the application “if convicted”, Other cases in which such information is required by law.
11. Automated decision-making
We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.
12. Data sharing: Why might you share my personal information with third parties?
We will share your personal information within our group of companies for Internal communication and branding, such as the production of staff newsletter, the use of internal communication systems such as the reward and recognition platform staffbravo.com.cy or the OASYS HR system, for the purposes of exploring the opportunity of an internal transfer or promotion, for training and development needs or feedback on a training.
We will only share your personal information with the following third parties for the purposes of processing and managing your initial application and employment with us :
– Investors in People Community Interest Company most widely known as Investors in People(“IIP”) to benchmark performance and create effective results, build dynamic relationships that help to evolve your talents and develop a supportive and engaging people management strategy.
– Theova UHS, Micro SMS – user profile/login credentials for job related tasks
– Staff Bravo – reward and recognition platform, self-registering
– Government departments / Social insurance / labor offices as required by law i.e. in case of sick leaves, maternity leave, accidents, parental leave or for the purposes of establishing proof that legal conformity is met / compliance with contractual agreements, legal requirements about working hours, service points, annual leave.
– The dedicated Medical Center in Limassol certified to perform Covid-19 testing as per government protocols based on Quarantine Law (Ν. 72(I)/2020)
Information to training consultancies for determining special approach to T&D, or to hotels abroad before sending employees under special training/internship schemes. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
13. Data security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties on a need-to-know basis. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected data security breaches and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
14. Data retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. [Details of retention periods for different aspects of your personal information are available in our retention policy which is available from the Data Protection Officer. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymize your personal information so that it can no longer be associated/identify with you, in which case we may use such information without further notice to you.
15. Rights of access, correction, erasure, and restriction
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
Under certain circumstances, by law, you have the right to:
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Object to processing of your personal information. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you.
Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our Data Protection Officer at [firstname.lastname@example.org]
16. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Data Protection Officer at email@example.com Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
17. Data protection officer
or contact them at:
Address: Iasonos 1, 1082 Nicosia, Cyprus
Postal address: P.O.Box 23378, 1682 Nicosia, Cyprus
Tel: +357 22818456
Fax: +357 22304565
18. Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.