Privacy Policy

Labour Mobility Application Portal

1. Introduction

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Skills and Labour Services Ltd (“we”, “us”, “our”) is committed to protecting the privacy, confidentiality, and security of personal data submitted through its Labour Mobility Application Portal (“Portal”)[cite: 101]. [cite_start]This Privacy Policy explains how we collect, use, store, share, and protect personal data of applicants seeking international employment opportunities, including placements in Germany, Ireland, and other destination countries[cite: 102]. [cite_start]By using the Portal, you consent to the practices described in this Privacy Policy[cite: 103].

2. Legal and Ethical Framework

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This Privacy Policy is guided by and compliant with[cite: 104, 105]:

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  • Nigeria Data Protection Act (NDPA) [cite: 106]
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  • Relevant principles of the EU General Data Protection Regulation (GDPR) [cite: 107]
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  • ILO Fair Recruitment Principles [cite: 108]
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  • International best practices for ethical recruitment and labour mobility [cite: 109]

3. Personal Data We Collect

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We may collect the following categories of personal data[cite: 111]:

3.1 Identity and Contact Information

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  • Full name, Date of birth, Gender, Nationality [cite: 113-116]
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  • Phone number, Email address, Residential address [cite: 117-119]

3.2 Professional and Employment Information

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  • Curriculum Vitae (CV) [cite: 121]
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  • Educational qualifications and certificates [cite: 122]
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  • Professional licenses and trade certifications [cite: 123]
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  • Employment history, Skills, competencies, and references [cite: 124, 125]

3.3 Identification and Travel Documents

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  • Passport bio-data page [cite: 127]
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  • National ID (where required) [cite: 128]
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  • Visa-related documentation (where applicable) [cite: 129]

3.4 Recruitment and Mobility Data

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  • Job preferences and application history [cite: 131]
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  • Interview records, assessments, and language proficiency records [cite: 132, 133]
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  • Pre-departure and onboarding information [cite: 134]

4. Purpose of Data Processing

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We process personal data strictly for legitimate recruitment and labour mobility purposes, including[cite: 136]:

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  • Assessing applicant eligibility and suitability [cite: 137]
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  • Matching applicants with potential foreign employers [cite: 138]
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  • Supporting recruitment, selection, and facilitation of visa/immigration assistance [cite: 139, 140]
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  • Pre-departure orientation and onboarding [cite: 141]
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  • Compliance with legal, regulatory, and contractual obligations [cite: 142]
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  • Communication with applicants regarding their applications [cite: 143]
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We do not process data for unrelated commercial or marketing purposes without explicit consent[cite: 144].

5. Legal Basis for Processing

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Personal data is processed based on lawful grounds such as applicant consent, performance of a contract, compliance with legal obligations, or legitimate interests where they do not override applicants’ rights [cite: 146-150].

6. Data Sharing and Disclosure

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Personal data may be shared only when necessary with[cite: 152]:

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  • Verified and vetted foreign employers [cite: 153]
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  • Immigration and visa authorities in destination countries [cite: 154]
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  • Accredited training institutions, assessment bodies, and partner organizations [cite: 155, 156]
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  • Regulatory or law enforcement agencies where required by law [cite: 157]
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We do not sell, rent, or trade applicants’ personal data[cite: 158].

7. Cross-Border Data Transfers

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As part of international labour mobility processes, personal data may be transferred outside Nigeria, including to Germany and Ireland[cite: 160]. [cite_start]Such transfers are conducted with appropriate safeguards, including data protection agreements, secure transmission methods, and compliance with international standards [cite: 161-164].

8. Data Retention

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We retain personal data only for as long as necessary to fulfil recruitment objectives, meet legal requirements, or resolve disputes [cite: 166-169]. [cite_start]When data is no longer required, it is securely deleted or anonymized[cite: 170].

9. Data Security

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We implement appropriate technical and organizational measures to protect personal data, including secure servers, encryption of sensitive data, restricted access, and regular system monitoring [cite: 172-176]. [cite_start]Despite these measures, no system can guarantee absolute security[cite: 177].

10. Applicant Rights

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Applicants have the right to[cite: 179]:

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  • Access their personal data [cite: 180]
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  • Request correction of inaccurate or incomplete data [cite: 181]
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  • Request deletion of personal data (subject to legal obligations) [cite: 182]
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  • Withdraw consent where processing is based on consent [cite: 183]
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  • Object to certain forms of processing [cite: 184]
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  • Lodge complaints with relevant data protection authorities [cite: 185]

11. Fair Recruitment and Non-Discrimination

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In line with ILO Fair Recruitment Principles, personal data is processed without discrimination based on gender, ethnicity, religion, age, disability, or social/economic background [cite: 188-194]. [cite_start]Data is used solely to assess professional suitability and legal eligibility[cite: 195].

12. Cookies and Portal Usage Data

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The Portal may collect limited technical data such as IP address, browser type, and login timestamps solely for system security, performance monitoring, and service improvement [cite: 197-201].

13. Changes to this Privacy Policy

We may update this Privacy Policy periodically to reflect legal, operational, or regulatory changes. [cite_start]Updated versions will be posted on the Portal, and continued use constitutes acceptance of the revised Policy[cite: 203, 204].

14. Contact Information

For questions, data requests, or privacy-related complaints, contact:
Skills and Labour Services Ltd
[cite_start]Abuja, Nigeria [cite: 206, 207]

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