PRIVACY STATEMENT ON PERSONAL DATA COLLECTION

    Overview

    This Privacy Statement outlines how Bahrain Mumtalakat Holding Company B.S.C (c) (“Mumtalakat”) processes Personal Data in the course of conducting its business activities.

    For the purposes of this privacy statement the following words and expressions shall have the following meaning:

    “Personal Data” (also referred to as “Data”) relates to any information that identifies or can lead to identify an individual (either directly or indirectly).  It includes but is not limited to an individual’s name, date of birth, business or personal contact details (telephone/mobile numbers, fax numbers, email IDs, physical and/or mailing address) bank account details, passport and smart card details including copies, photographs, BIOs/Curriculum Vitae, personal/educational/employment/medical history and current details etc.

    “Sensitive Personal Data” means any personal information that reveals – even indirectly – an individual’s race, ethnicity, political or philosophical views, religious beliefs, union affiliation, sexual orientation or criminal record and any medical data, such as medical reports or certificate of good conduct.

    “Processing or Process” includes collecting, recording, organising, classifying into groups, storing, adapting, altering, retrieving, using, disclosing, transmitting, transferring, combining, blocking, erasing or destroying any Personal Data.

    Personal Data (both electronic and hard copy) that is collected or received by Mumtalakat may be Processed by various departments at Mumtalakat, which includes but is not limited to Human Resources (HR), Communications & Public Affairs, Information Technology (IT), Legal, Finance etc, depending on the purpose for which such Data has been obtained.

    Processing of Personal Data

    Mumtalakat Processes Data in relation to the following:

    Job Applications

    Job vacancies at Mumtalakat are generally announced on the Careers Page of our website. In some cases, Mumtalakat may engage the services of an external recruitment agency to support our hiring process.  In such instances, the selected agency will collect Data on behalf of Mumtalakat which in turn will be submitted to Mumtalakat’s HR Department for further action.  All Personal Data pertaining to individuals who apply for job vacancies at Mumtalakat, whether through our website Careers Page or through an external recruitment agency, will be Processed by Mumtalakat.  For applications submitted through an external recruitment agency, the respective agency’s data collection and retention policy will also need to be considered by the applicant.  The Data collected will be used to assess the suitability of the applicant/individual for the job vacancy at hand in the interest of attracting the most apt candidate for the said position(s). The Personal Data collected may also be shared with Mumtalakat’s group of companies with the intention of supporting the recruitment processes at our portfolio companies.  Furthermore, as part of the recruitment process, the Data may also be transmitted to relevant local authorities as part of the vetting/screening process.  Successful applicants/candidates will be provided with more information on the Processing of their Personal Data by the HR Department as part of their offer and onboarding process.  Please note that by submission of your Personal Data and Sensitive Personal Data and CVs, either through our website Careers Page Application Form or through external agencies administering the recruitment process on our behalf, you are giving Mumtalakat your full consent to Process your Personal Data and Sensitive Personal Data by electronic or non-electronic means as may be required for the purposes of processing your job application.

    Business Partners, Suppliers and Service Providers (Third Parties)

    Personal Data related to our business partners, suppliers and service providers (also collectively referred to as “Third Parties” in this context), as well as related to individuals connected with such Third Parties, such as owners, shareholders, directors, board members, senior management and key personnel, is Processed by Mumtalakat as necessary.  Such Data may be Processed for the purpose of furthering Mumtalakat’s business interests and objectives, to consider bids and tenders for various goods and services, to conclude and execute agreements with such Third Parties to accomplish the requisite business objectives and/or for the provision of the requisite goods and services, to comply with local regulations and legal requirements, and to communicate with, support and manage the aforementioned agreement and resulting relationships with such Third Parties.  Such Data may be collected from the Third Parties with whom Mumtalakat would like to establish business partnerships with and/or solicit goods, services, information or feedback or vice versa through face to face meetings, telephone calls, bidding processes, events, email exchanges, surveys, questionnaires, either directly or through external agencies authorised to obtain such Data on behalf of Mumtalakat.  In addition, Data from potential Third Parties seeking business opportunities from Mumtalakat will also be collected via our website Contact Us form.  From time to time, Mumtalakat may also screen and conduct due diligence of existing and potential Third Parties, as well as of individuals related to existing and potential Third Parties, to determine capabilities, to evaluate the outcome and success of the business relationship, and to assess the timeliness and quality of the required goods, services, information and feedback.  Such screening and due diligence may be conducted by Mumtalakat or by external agencies specialising in the provision of such services.  The Data collected for the purpose of such screening and due diligence will depend on the type of Third Parties and the potential risks involved, but will generally include name, business role, contact information, listings in sanctions or restricted lists, political exposure, as well as information related to corruption, crime, regulatory fines and penalties.  In addition to being Processed at Mumtalakat, all such Data collected may also be transmitted to our group of companies, local authorities and external agencies as required, as part of achieving the aforementioned purposes.  All such Data collected will be archived at Mumtalakat for record purposes.

    Online Engagements & Outreach Efforts

    In order to support our online engagement and outreach efforts, we use images of our staff members as well as that of colleagues from our group of companies.  Such images are typically used to furnish our website, annual reports, social media platforms such as Twitter, Facebook, Instagram, YouTube and LinkedIn, campaigns and as supplementary footage to any corporate video or interview productions.  All such images, which may or may not be supported by the names, designations and organisation information of the featured individuals, are obtained upon receipt of a signed consent form from the individual(s) concerned (“Consent Form”).  In order to support the development of creative content to support the abovementioned usages, the services of external service providers such as design companies, photographers, videographers etc may be sought.  In such cases, images and relevant supporting Personal Data in their original form may be supplied to the service providers concerned to facilitate provision of the requisite services or new images/footage of the participating individuals may be obtained via photography/videography services.  Such exchange of Personal Data with external service providers is governed by a signed agreement that outlines conditions of confidentiality and security.  All such images and related Personal Data will be Processed by Mumtalakat as applicable in order to meet its online engagement and outreach requirements.  By signing the Consent Form, participating individuals give Mumtalakat their full consent to the Processing of their images for the above-mentioned purposes.

    Website Cookies

    Cookies are files containing small amounts of information which are downloaded to the device you use when you visit our website, mumtalakat.bh. These files enable us to recognise our website visitors’ web browser and know from which country, region and city they are visiting our site, but does not give us any directly identifiable information about the visitors, such as their names, address etc. We use cookies to optimise the performance of website, in order to adapt and deliver webpages that cater to our visitors/audiences’ interest.  In order to achieve this, we collect information about which browser our website visitors use and their internet speed.  Furthermore, the cookies also enable us to analyse the number of unique visitors we have and whether our website has previously been visited by the same device/browser. This information is used in order to develop and improve our website by detecting which pages generate the most traffic and whether our pages are working properly or not. In addition to the cookies that are used by Mumtalakat, we also grant permission to certain third parties who deliver services to us, such as Google Analytics, to use cookies. Information about how Google uses collected Data is available here: https://www.google.com/policies/privacy/partners/

    In order to view or delete the cookies that have been stored on your device, please see the settings in your web browser.   Your web browser normally stores cookies in a specific folder on your hard disk as well, where you can examine the contents in more detail.  Please bear in mind that disabling cookies may prevent our website from working properly.

    Website Contact Us Form

    Potential Third Parties, job seekers and any other third party may contact us by submitting a request via our website Contact Us form.  Depending on the subject chosen, the request is directed to the concerned department for review and further action as applicable.  The Personal Data and Sensitive Personal Data that is submitted to us via the Contact Us form will be Processed as required for any of the aforementioned purposes. Please note that by submission of your Personal Data and Sensitive Personal Data through the Contact Us form, you are giving Mumtalakat full consent to Process your Data as necessary to process your request or address your enquiry.

    Contacts Database

    We endeavour to develop and maintain a comprehensive database of contact information related to our portfolio companies, Third Parties, job seekers/applicants and media partners.  The database typically comprises of individual names, designations, name of the organisation, telephone, mobile and fax numbers, email IDs, physical and mailing address, CVs, website URLs, social media accounts, location maps etc.  The purpose of developing and maintaining such a database is to enable us to reach out and communicate with the parties concerned in a timely manner with the ultimate aim of conducting our business in an efficient and effective manner.  The database is regularly reviewed and updated to ensure accuracy.  The Personal Data to populate and update the database may be collected by Mumtalakat via telephone calls, emails exchanges, receipt or dispatch of letters, online research or during registrations at meetings and events.  In addition, relevant Personal Data that is received via our website Contact Us form may also be used to supplement the database.  Furthermore, Data is also collected from individuals visiting our offices in order to notify the concerned departments or staff member(s) of the arrival of the said individual as well as to inform our building management team, reception and parking area personnel as applicable for logistical and security purposes. The database will be accessible to all departments and staff members at Mumtalakat for internal business purposes and to enable staff members to perform their respective official duties.  The database or parts of it may also be shared with Mumtalakat’s group of companies to assist them in contacting certain companies or individuals as part of conducting their respective businesses, and with local authorities as applicable as part of any legal or investigative inquiries.  Please note that by providing us with your Personal Data, you give Mumtalakat full consent to Process your Data as required for the above-mentioned purposes.

    Surveillance

    Visitors to Mumtalakat and Arcapita building which includes our staff members, interns, consultants, service providers, existing and/or potential business partners, media, general guests etc should be aware that CCTV cameras are installed by Arcapita building management at various locations within the building in line with local security regulations.  The footage that is filmed will be Processed for security purposes only and will be transmitted to relevant local authorities in the event of any security related concerns or incidents.

    Transmission of Personal Data

    Access to Personal Data is primarily limited to Mumtalakat’s management and personnel who have appropriate authorisation and a clear business need for the information. Mumtalakat will only share personal data on a need to know basis with its group of companies, authorised suppliers, service providers, external agencies and professional advisors, and otherwise as set out above and where it is necessary for compliance with legal obligations, such as to local authorities (including law enforcement and supervisory authorities).  We use external service providers to provide different types of services on our behalf, such as to operate our recruitment system, IT systems, to host our website and to perform background and due diligence checks. We ensure the security and confidentiality of their processing by entering into Non-Disclosure Agreements that outline the requisite measures for confidentiality.

    Security of Personal Data

    We process Personal Data securely and maintain appropriate technical, physical and organisational measures to protect the Data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access.  Should a Personal Data breach occur that is likely to result in a high risk to the rights and freedoms of the individuals affected, we will communicate this without undue delay and take necessary action to mitigate those risks.

    Retention and Deletion of Personal Data

    Personal Data will only be retained by us for as long as it is necessary to fulfill the purposes it has been collected for and for the purposes of satisfying any legal, archiving, accounting or reporting requirements. We determine the retention period for the different types of Personal Data based on the amount, nature and sensitivity of the Data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we Process Personal Data, limitation periods for claims and applicable legal requirements.

    Your Rights

    If we have Processed your Personal Data, you are entitled to certain rights. The rights you have are pursuant to the circumstances and applicable law, but they typically include:

    • The right to be informed upon request of what Personal Data, if any, we Process about you, and to receive a copy of that Data.
    • The right to request to have incomplete or incorrect Personal Data rectified or deleted
    • The right to withdraw your consent to the Processing of your Personal Data
    • The right to request that some or all of the Processing of your Personal Data is restricted or object to the processing of your Personal Data

    Please note that your right to object to the Processing of your Personal Data is not applicable in the following circumstances:

    • If you have given your consent to the Processing of your Personal Data;
    • If the Processing of your Personal Data is required for the performance of contractual obligation where you are a party to it;
    • If the Processing of your Personal Data was at your request;
    • If the Processing of your Personal Data is required for the performance of a legal obligation or order issued by the Court of Public Prosecution; or
    • If the Processing of your Personal Data is necessary to protect the legitimate interest of Mumtalakat.

    If you need further information or wish to exercise your rights, or if you wish to make a complaint regarding our handling of your Personal Data, please contact our Legal Department on legalaffairs@bmhc.bh.