Employee and Candidate Privacy Notice
For the people we employ or recruit: what we hold about you, why, who sees it, how long we keep it and your rights.
- Version
- 1.0
- In force from
- Last updated
1. Who we are
We are Moha. If we employ you, we are your legal employer in the UAE: you are on our MOHRE file and our visa, we sign your employment contract, and we pay you through the Wage Protection System (WPS). You work day to day for one of our client companies.
If you are a candidate, we hold your details to check whether you can get a work permit and a visa, and to hire you if the offer goes ahead.
This notice explains what we do with your personal data. Our Privacy Policy has the full detail.
2. What we hold
- Identity and contact: your name, nationality, date of birth, address, email and phone.
- Documents: your passport, visa, Emirates ID, photo, and education and experience certificates.
- Work and pay: your job title, contract, salary and allowances, bank account (IBAN), leave, expense claims and, at the end, your final settlement.
- Health: the result of your medical fitness test and your health insurance details. Only what the law needs.
- Family members, if we sponsor their visas: their names, passports, and marriage and birth certificates.
- Your platform account, if you have one: your sign-ins and what you do in it.
3. Why we hold it
- To employ and pay you: your contract, your work permit, your visa and Emirates ID, your health insurance, your salary through WPS, pension contributions where they apply, your leave and your final settlement.
- To meet the law: the records the Labour Law requires, audits, and requests from authorities.
The Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) lets us do this without asking for your consent, because we need it to meet our duties as your employer, to carry out your employment contract and to meet other legal duties (Article 4).
We never use your data to market to you, and we never sell it.
4. Who sees it
- MOHRE, for your work permit and contract, and ICP or GDRFA, for your visa and Emirates ID.
- The medical fitness centre, for your medical test.
- Your bank, through WPS, to pay your salary.
- Insurers, for your health insurance and the other insurance the law requires.
- The pension authority, if pension contributions apply to you.
- The client company you work for, only as far as the work needs, such as your name, job title, start date and leave. Pay details only reach the people there whose role needs them.
- Our hosting provider, Render, which keeps our platform’s data in Frankfurt, Germany, and handles it on our instructions.
Each one gets only what it needs.
5. How long we keep it
While you work with us, then at least 2 years after you leave, as Article 13 of the Labour Law requires. Some records, such as tax records, are kept longer where another law requires it.
If you are a candidate and we don’t hire you, we delete your details after 12 months.
6. Your rights
Under the Personal Data Protection Law (Articles 13 to 18), you can ask us:
- What data we hold about you, why, and who we share it with.
- For a copy of it.
- To correct or complete it.
- To delete it, restrict its use or stop using it, where the law allows. We can’t delete what the law makes us keep, such as your file for 2 years after you leave, and we tell you when that applies.
- For a person to review a decision made about you by automated means alone.
Email us at contact@employerofrecord.ae from the address we know you by. We reply within 30 days. If you have an account, you can also see many of your details in the platform.
7. Complaints
Tell us first at contact@employerofrecord.ae, and we will try to put it right. You can also complain to the UAE Data Office, the federal data regulator (Article 24).
For a problem with your employment itself, such as late pay, you can also go to MOHRE.
8. You never pay to work for us
We never charge you any fee to recruit or employ you. Article 6 of the Labour Law forbids it. If anyone asks you for money in our name, don’t pay, and tell us.
9. Changes to this notice
We update this notice when what we do changes. The version and the date at the top show which one you are reading.
The law behind it
- Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (u.ae)
- Federal Decree-Law No. 45 of 2021, full text in Arabic (u.ae)
- The UAE Data Office, the federal data regulator (u.ae)
- Federal Decree-Law No. 33 of 2021 and its amendments, full text in English (u.ae, a courtesy translation: the Arabic prevails)