Employment Privacy Notice
Last updated: 03/07/2025
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1. Introduction
4GL Concepts Ltd ("we", "us", "our") is committed to ensuring the security and privacy of your personal data. This Privacy Notice outlines how we collect, use, disclose, and protect your personal information during and after your employment with us, in accordance with the Gibraltar General Data Protection Regulation (Gibraltar GDPR).
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2. Who We Are
Company Name: 4GL Concepts Ltd
Address: Unit 23, Harbours Yard, New Harbours, Gibraltar, GX11 1AA
Email: info@4glconcepts.com
Telephone: +350 200 40316
Data Protection Officer: Robin Fitzpatrick
3. What Personal Data We Collect
We may collect and process the following categories of personal data:
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Identification data (e.g., full name, date of birth, nationality)
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Contact details (e.g., address, email, phone)
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Employment records (e.g., job title, salary, performance, disciplinary records, attendance)
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HR and payroll data (e.g., bank account, tax ID, social insurance details)
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Health and safety data (e.g., sickness records, medical certificates, occupational health reports)
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Right to work and compliance documentation (e.g., passport, visa, work permits)
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IT and communications data (e.g., email, internet usage, access logs)
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Emergency contact and dependent details
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Some of this data may include special category data, such as health information, collected where necessary and lawful.
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4. How We Collect Your Data
We collect data:
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Directly from you during onboarding or throughout employment
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From internal systems and interactions (e.g., timekeeping, email)
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From third parties, such as:
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References or previous employers
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Background screening providers (where applicable)
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Publicly available sources (e.g., professional profiles)​
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5. Purposes and Legal Bases for Processing
We process your data for:
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Where we process special category data (e.g., health), we do so with appropriate safeguards and based on legal grounds under Article 9 of the Gibraltar GDPR.
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6. Sharing Your Data
We may share your data with:
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Payroll and benefits providers
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Government authorities (e.g., Tax Office, Social Insurance)
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Legal and professional advisors
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Occupational health and safety providers
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IT and system administrators
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Regulatory authorities, when required
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All third parties are required to protect your data and only use it for the specified purposes.
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7. International Transfers
Your data is generally processed within Gibraltar or the EEA. If it is transferred outside the EEA, we ensure appropriate safeguards (e.g., Standard Contractual Clauses) are in place to protect your rights.
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8. Data Retention
We retain your personal data during your employment and for a minimum of 6 years after the end of your employment to comply with legal, tax, and contractual obligations.
Some data may be kept longer if required by law or for legitimate business purposes.
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9. Your Rights
Under the Gibraltar GDPR, you have the right to:
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Access your personal data
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Rectify inaccuracies
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Erase your data (in certain circumstances)
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Restrict or object to processing
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Data portability (where applicable)
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Withdraw consent (if processing is based on consent)
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Lodge a complaint with the Gibraltar Regulatory Authority (GRA)
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To exercise your rights, contact: info@4glconcepts.com.
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10. Automated Decision-Making
We do not rely on automated decision-making that produces legal or similarly significant effects on employees.
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11. Updates to This Notice
We may update this notice periodically. Employees will be notified of significant changes and the latest version will always be available via the company website.
Purpose
Administering your employment
Paying salary and benefits
Compliance with legal and regulatory obligations
Managing performance, training, and development
Ensuring workplace health and safety
Monitoring IT systems for security
Processing leave, sickness, or family-related absences
Handling disciplinary or grievance matters
Legal Basis
Performance of contract
Legal obligation; performance of contract
Legal obligation
Legitimate interest; performance of contract
Legal obligation
Legitimate interest
Legal obligation; consent (in certain cases)
Performance of contract; legal obligation