Privacy Notice


Date issued: May 2018

Updated: January 2023


Thomas Smith & Co Ltd, TC Smith Agencies Ltd, TS Container Agencies Ltd, Thomas Smith Insurance Agency Ltd (registered office 1, War Victims Square, Luqa LQA 1010, Malta) and Thomas Smith Insurance Brokers Ltd (registered office 2, Triq Guzeppi Ellul, Luqa LQA1154, Malta) (together ‘Thomas Smith’, ‘Us’ or ‘We’) acknowledge the importance of privacy to you and are fully committed to respecting your privacy as well as protecting your personal data. The scope of this Recruitment Privacy Notice (‘Privacy Notice’) is to clearly describe how We, on receipt of your application, process your information for recruitment purposes and protect your personal data. All information received is utilised for the sole purposes outlined in this Privacy Notice. Access to personal data is limited to authorised personnel within the Thomas Smith group, who are in turn required to maintain data confidentiality.

‘Personal Data’ means information submitted through your online registration, an online application, recruitment firm, or referral through which you as a job applicant and/or potential candidate, can be identified as an individual person.

In submitting personal data, you as a job applicant or potential candidate, acknowledge that you have read and understood this Privacy Notice, give consent to the utilisation of your personal data as outlined in this Privacy Notice and confirm that all personal data provided is true and correct at the time of submission.


Profile Creation

Data is stored by us when a profile is created from our website. Your profile may be created in 2 ways: a) directly by you in which case you will need to read and accept this Privacy Notice; b) by us if you forward your information to us via email or any other means. Once a profile is created by us, you will receive an email with a verification link which you will need to activate your profile. If after 3 months, you have still not verified your profile, we will proceed to delete it and any data which would have been stored. Should you have any queries in this regard, please email us on [email protected].  

All profiles created, whether by you or by us on your behalf, are created on a system called Talexio which is wholly owned by Talexio Limited. 

Where you create a profile directly but no CV is uploaded by you, you will receive an automated email within 30 minutes asking you to upload your CV in order for us to be in a position to assist. Should you fail to do so, reminders to upload your CV are sent after 3 days and subsequently after 10 days. Should you not upload a CV within 3 months, your profile will be disabled. 

When a profile is created, you shall have full access to the data that you have entered and have the facility to change, delete, amend or modify this data independently. You shall have full responsibility for the accuracy and completeness of the data that you have entered. Once a profile is fully active, you may be contacted in order to identify possibilities of assistance from our end. We may or may not enable or disable job alerts based on your preferences. When you are approached by us in relation to a specific vacancy or a company, you shall be given full disclosure of the company’s details and your consent is essential for us to proceed. 

Should your profile not show any activity for a period of one (1) calendar year, you will receive an automated email asking you to activate your profile in order to ensure your profile will not be deleted by us. Should you not activate or re-activate your profile for a continuous period of ten (10) calendar years, your profile and all data which would have been stored by us will be deleted. 

Collection of Personal Data

On receipt of your application and CV for a position at Thomas Smith, We collect and process different types of information including:

  • Personal details including name, address, date of birth, educational qualifications, work experience, skills and employment history given to Us by you.
  • Other details of your application including the role applied for and the platforms utilised to apply for a vacancy.

Use of Personal Data

 We collect and use personal data given to Us by you to:

  • Consider your application in respect to the role for which you have applied.
  • Consider and match your profile to other potential opportunities within Thomas Smith.
  • Contact you throughout the progress of your application.
  • Answer any queries which you may have.

Sharing of Data

Application for a Specific Role: We will share your personal data with relevant departmental managers responsible for the role which you are applying for.  Your CV may also be shared with other relevant managers within the Thomas Smith group for consideration in an alternative role suiting your profile.

Open Application: On receipt of your ‘open’ application where the profile matches a particular role, your personal data will be shared with the relevant departmental manager/s within the Thomas Smith group.

Retention of Personal Data  

Candidates offered employment: Relevant personal data of candidates, who would have been offered and have accepted an employment offer and which would have been collected during the pre-employment phase, will be moved to the personnel records and will be retained according to local legislation. Further processing of your personal data may also be required if a work permit is being applied for.

Other Candidates: All personal data of candidates who have not been offered employment will be held for 12 to 18 months from the date of receipt of data. Such personal data will be utilised to consider you as a candidate for a potential future role fitting your profile.

Deletion of Personal Data

Your details will be deleted from the recruitment system of Thomas Smith after a maximum of 18 months from the date of receipt of your details. Personal information will however also be immediately deleted upon receipt of written request of ‘deletion of personal information’ by you the candidate.

Storage of Personal Data

Appropriate measures are taken by Us to ensure that all personal data is securely kept internally.  Access to personal data is also limited to authorised personnel within the Thomas Smith group, who are bound by a duty of confidentiality. Security of your data transmission utilising an online means cannot however be guaranteed and remains at the candidate’s own risk.

Your Rights

We aim to ensure that personal data held about you is accurate and up to date.  In this respect you also have the right to:

  • Request access to your personal data.
  • Request that We correct any mistakes in information held about you by Us.
  • Request that We delete personal data held about you by Us.

If you want to exercise any of these rights you can contact Us on [email protected].

Requests have to be done in writing and proof of your identity will be required for any amendments and/or deletions of Personal Data.


Any queries about this Privacy Notice or about information which We hold about you are to be sent to: [email protected]

Changes to our Privacy Notice

Thomas Smith reserves the right to amend this Privacy Notice. Any changes made to our Privacy Notice will be posted on this page.