Legal

Employee privacy notice

What we hold about the people who work here, and the four things we will never do.

Provisional: this document is not approved yet

Everything below is a draft. It becomes the studio's approved position only when every administrator has signed this exact version in the client area. Until then, read it as an accurate description of what we do and intend, not as a document anybody has signed off.

Written in-house, not reviewed by a lawyer, and no Maltese entity exists yet to be a party to it. What approval means here

This is what happens to personal data about the people who work at the studio behind Getaway Gaming: employees, contractors and anybody else with a sign-in. It is published rather than kept in a handbook because the person it matters most to is somebody deciding whether to apply, and they cannot read a handbook.

There are no employees yet. Writing it now is the cheapest moment to commit to it, and every refusal below is easier to make today than it would be after somebody has built the thing being refused.

What we hold

CategoryWhat it is, and why
Your identity and your roleName, work email, job title, start date, and the internal role that decides what you may reach. GLI-19 §2.8.9 requires a supplier to be able to say who had which account and when, so these are recorded rather than assumed.
Employment and payrollYour contract, your pay, your bank details, your tax and social-security identifiers, absence and leave. Held because an employment contract and the tax law of the country you are employed in require it.
What you did in our systemsCommits, pull requests, the access log, which production action you took and when. This is a change-control record, which is what a laboratory and a regulator ask to see. It is not a productivity measure.
Access grantsWho gave you a role, for what stated reason, from when and until when, and who took it away. Append-only.
Probity information, for key-function roles onlyWhere a role is one a gaming authority must personally approve, that authority's own fit-and-proper process. See below.

On what basis

Most of it is article 6(1)(b), because we cannot employ you without it, and article 6(1)(c), because payroll, tax and social security are legal obligations rather than choices. The access log and the change-control record are article 6(1)(f): running a controlled system that a laboratory can audit, which is also the thing that protects you when somebody asks who made a change.

Consent is deliberately almost absent. Between an employer and an employee consent is rarely freely given, because the relationship is unequal, so we do not build processing on it. The exceptions are the obvious ones where a no costs you nothing: a photograph on the website, your name in a release note.

What we will not do

Written before anybody is employed here, so these are commitments made in advance.

No reading of your messages, no keystroke logging, no screen recording, no screenshot agent, no webcam, no microphone, and nothing on a personal device.

No productivity scoring, no ranking of people by output, no commit-count league table, and no AI tool that summarises or assesses an individual's work. The access log records what was reached in a controlled system; it is not a timesheet and will not be read as one.

No location tracking of any kind. No monitoring of what you do outside work, including on social media.

No automated decision with a legal or similarly significant effect about you. A person decides about hiring, pay, promotion and discipline, and that person can be asked why.

What a gaming authority will be told, and about whom

A licensed gaming supplier has key functions (compliance, technical, finance and anti-money laundering among them), and the authority approves the named person holding each one. That process looks at the individual: identity documents, a criminal record check, sources of wealth, directorships, and in some jurisdictions a declaration from close family.

That is the most intrusive thing that will ever happen to your data here, it is a statutory process we cannot waive, and it only reaches the handful of roles the authority names. If you are offered one of them, this is part of what is being offered and we will say so before you accept rather than afterwards.

Today none of it happens, because we hold no licence. The section exists so that it is not a surprise on the day we do.

Who else sees any of it

Payroll and tax authorities, the pension and insurance providers your contract names, and our accountants. A gaming authority, for a key-function role. A laboratory or auditor, where they are examining a change you authorised. What they see is your name against a decision, not your file.

Nobody else. Your record is not sold, not shared with a recruiter, not used to train anything, and not transferred outside the EEA except where a provider your contract names operates there under Standard Contractual Clauses.

How long it is kept

WhatHow long
Your employment recordSix years after you leave, which is what a claim arising from the employment could still need.
Payroll and taxThe period the tax law of your country of employment sets. Usually seven years, and it is not ours to shorten.
Access grants and the access logAppend-only, for the period a regulator or test house may ask to see. The register is designed to be complete.
Commits and change recordsFor the life of the repository. A certified build has to be reconstructible from them.
Your name in a release note or a certification packPermanently. It is a record of who authorised something, and removing it would be falsifying the record.

Your rights, and the two real limits

Access, rectification, erasure, restriction, portability, and objection to anything we do on the basis of legitimate interests. That includes the access log, where we will answer with the specific regulatory reason rather than a general one.

The limits: we cannot delete a payroll record the tax law requires us to keep, and we cannot remove your name from a change-control record or a certification pack, because that record's value is that it is complete. Everything else is negotiable and asking will never count against you.

There is nobody to complain to about your manager yet

A notice like this normally names an HR function and an escalation route. There is neither, because there is nobody employed here. Until there is, the route for anything about this notice is the inbox below, and the route for a concern you cannot raise internally is on the business conduct page. That page says that in a studio this small the founders are the channel, and where to go when the concern is about one of them.

Contact

Write to hello@getawaygaming.com. You may also complain to Malta's Information and Data Protection Commissioner, or to the authority where you live, without asking us first.

Provisional until every administrator has approved this version. Written in-house, not reviewed by a lawyer, and no Maltese entity exists yet to be a party to it.

The candidate privacy notice