Privacy Policy
1. Introduction
The Labour Fund (“Tamkeen”) respects your privacy and is committed to protecting your personal data. This Privacy Policy (the “Policy”) applies to Tamkeen’s platforms including but not limited to Tamkeen Website and application process through Tamkeen Portal.
2. Purpose of this Privacy Policy
This Policy aims to provide you with information on how Tamkeen collects and processes your personal data through your use of this website and Tamkeen Portal, including any data you may provide through this website and/or Tamkeen’s application process.
It is important that you read this Policy together with any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.
3. Controller
Tamkeen is the controller and responsible for your personal data (collectively referred to as Tamkeen, ‘we’, ‘us’ or ‘our’ in this Policy).
If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the Information Security and Compliance unit using the details set out below:
DPG@tamkeen.bh, Tamkeen, P.O. Box 18131, Manama, Bahrain
4. Changes to the Policy and Your Duty to Inform us of Changes to Your Personal Data
We keep our Policy under regular review, and accordingly, our Policy may be subject to changes from time to time at Tamkeen’s sole discretion.
In relation to personal data, it is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
5. Third-party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
6. Personal Data and Sensitive Personal Data
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). Sensitive personal data means any personal information that reveals, directly or indirectly, the individual’s race, ethnicity, genetic, biometric data used for identification purposes, political or philosophical views, religious beliefs, union affiliation, criminal record or any data related to his/her health or sexual life.
We may collect, use, store and transfer different kinds of personal data and/or sensitive personal data about you which we have grouped together as follows:
a) Identity Data: full name, gender, nationality, date of birth, title, username or similar identifier, photograph and/or video.
b) Contact Data: contact and address details including telephone numbers and email addresses.
c) Education Data.
d) Employment Data: employment letter, designation, hiring date and training provider acceptance letter (if applicable).
e) Identification Data: identification numbers issued by government bodies (for example: CPR, passport copy, driver’s license number and other government-issued identity numbers) and biometric data where required.
f) Financial Data: including credit card data, copy of salary slip or income statement, IBAN online verification and bank account information, financial transactions and status.
g) Voice and video recording through customer services.
h) Technical and Usage Data: internet protocol (IP) address, login data, date and duration of website visit, pages visited, browser type and version, time zone setting and location, browser plug-in types and versions, operation system and platform, and other technology on devices used to access the Tamkeen website and Portal.
i) Profile Data: username and password, preferences, feedback and survey responses.
j) Marketing and Communications Data: preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. If this changes, i.e. aggregated data is connected or combined with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data used in accordance with this Policy.
Where required by law to collect your personal data or under the terms and conditions of a contract between us, and you fail to provide the personal data requested, Tamkeen may not be in the position to provide services to you under the Tamkeen website or Tamkeen Portal.
7. Tamkeen Collects Your Personal Data Using Different Methods
a) Directly from you via different communication channels such as emails, phone calls, face-to-face meetings or online during registration/creation of an account process and completion of application forms, during the payment process, providing us with feedback or contacting us and during your engagement with Tamkeen and/ or its employees to provide you with services.
b) Automated technologies or interactions – as you interact with our website or Portal, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
c) Indirectly from your employers, external agencies coordinators, partner entities, through Tamkeen’s social media platforms and website, and/or by fetching your personal data from governmental entities or financial institutions e.g. Ministry of Labour & Social Development (MOLSD), Ministry of Industry, Commerce (MOIC), Labour Market Regulatory Authority (LMRA), Social Insurance Organization (SIO), Ministry of Education (MoE), Tawasul Portal, National Bureau for Revenue (NBR), Benefit, Central Informatics Organisation, Ministry of Justice, Customs Affairs, Information and eGovernment Authority and any other relevant authority/governmental organisation.
8. Purposes for Personal Data Collection and Lawful Basis for Processing
Tamkeen will only use your personal data including sensitive personal data within the confines of the law (legal/regulatory obligations, contractual obligations, data subject consent and legitimate interests). Most commonly, we will use your personal data in the following circumstances:
- To perform the contract and provide services.
- To support Bahrainis to enhance their skills, career development, progression, and support them to develop their business ideas.
- To support Enterprises established in Bahrain by enhancing their business operations, human capital development and helping them to develop and grow.
- To handle customers’ requests and inquiries regarding Tamkeen’s products and services, through customer service channels.
- To analyse information to understand current and potential market needs for program design, development, amendment, and policy refinement.
- To ensure effective control over Tamkeen’s document drafting and review for internal and external matters.
- To respond to interested parties’ requests and to manage litigation procedures in-case Tamkeen is party.
- For fraud/violation investigation, reporting and resolution.
- To monitor approved contracts by Tamkeen to ensure compliances to the contractual obligations and the internal policies and procedures applicable and agreed outcomes and KPIs.
- To ensure essential Tamkeen information and software are backed up, and to allow efficient and timely recovery of IT systems and data after a disruption.
- To manage internal and external portals by IT.
- For making payments related to the schemes/ programs.
- To manage social media channels, e-content, posting, website content and bulk emails.
- To create and execute events to maintain brand image, reach existing and potential customers and assist in organizing events falling under Tamkeen’s objectives.
- To perform projects risk assessment validation and to perform due diligence activities on partners.
- To compliment programs activities and processes through sharing data to internal and external stakeholders.
- Where necessary for the protection of Tamkeen’s legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- To comply with a legal obligation.
9. Categories of Recipients of Your Personal Data
Your personal data will be processed by Tamkeen’s concerned employees, and may be shared with third-parties including but not limited to cloud providers for email communication and Disaster Recovery storage, governmental entities/authorities for systems’ integration and data sharing (MOLSD, NBR, SIO, MOIC, LMRA, Central Informatics Organisation, Ministry of Justice, Customs Affairs, Information and eGovernment Authority, Benefit), outsourced third parties, partner banks, external agencies, and where we have one of the above-mentioned legitimate interests in doing so.
10. Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website and/or Tamkeen Portal may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
11. Your Legal Rights
You have the right to request:
- Access to your personal data.
- Rectification/modification or correction to your personal data.
- Remove, block or restrict your personal data.
- Object if your personal data is being used for direct marketing
- Object if processing may result in defamation or discrimination causing possible financial or moral damage.
- Object if your personal data is being used for decisions based on automated data processing and request that another method is adopted.
- Withdraw your consent to the processing of your personal data in cases where you have provided your consent for the processing and, as such, your consent is the lawful basis that Tamkeen is relying on for processing.
Tamkeen shall process such requests free of any charges within a period of 10 working days from receipt of the request in accordance with the relevant laws. You have the right to lodge a complaint to the Bahrain Personal Data Protection Authority regarding related violations concerning the processing/use of your personal data.
12. Security Measure
Your personal data is protected under the relevant laws of the Kingdom of Bahrain and Tamkeen has put in place appropriate security measures to prevent your personal data from being accidentally lost, altered, disclosed or accessed in an unauthorized way.
13. Retention Period of Your Personal Data
Tamkeen retains your personal data based on the validity of the contract, legal, regulatory, tax, accounting or reporting retention period requirements, fulfilling its intended purposes, and historical archiving. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. Subject to the retention periods described above, we securely destroy and erase or anonymize your personal data (so that it can no longer be associated with you) to ensure that it cannot be restored after exceeding the retention criteria. You will no longer be notified if Tamkeen uses the anonymized data for research and statistical purposes. Should there be any further requests for amendment to personal data, objection to processing or withdrawal beyond the prescribed retention periods, Tamkeen will not be able to support you with any further processing.