This Data Protection Policy (“Policy”) sets out the basis which Celecti Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our candidate/job applicant in accordance with the Personal Data Protection Act (“PDPA”). This policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our services of recruiting and placing individuals for potential work assignments (and related services) with our customers.
1. APPLICATION OF THIS POLICY
This Policy applies to all persons who have applied for any job position with us (“candidate/job applicant”).
2. DEFINITION OF PERSONAL DATA
2.1. Personal data refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access.
2.2. If you are a candidate/job applicant, personal data which we may collect includes, without limitation, your:
– name or alias, gender, date of birth, nationality, and country and city of birth;
– mailing address, telephone numbers, email address and other contact details;
– resume, educational qualifications, professional qualifications and certifications and
– employment references;
– employment and training history;
– work-related health issues and disabilities;
– photographs; and
– any additional information provided to us by you.
2.3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
3. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
3.1. Collection of Personal Data
We generally do not collect your personal data unless:
3.1.1. it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after:
(i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and
(ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or
3.1.2. collection and use of personal data without consent is permitted or required by the PDPA or other laws. Providing us with your Personal Data is voluntary. However, if you choose not to provide us with the Personal Data described in this Policy, we may not be able to fulfill our contractual duties towards you or facilitate your request or provide the service to you, or the company you may be representing.
3.1.3. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
3.2. Use of Personal Data
Assessing and evaluating your suitability for employment in any potential recruitment opportunities; and verifying your identity and the accuracy of your personal details and other information provided.
3.3. Disclosure of Personal Data
3.3.1. We may disclose your personal data:
(i) where such disclosure is required for performing obligations in the course of or in connection with our provision of the job application requested by you; or
(ii) to third-party service providers, agents and other organisations we have engaged to perform any of the functions.
3.3.2. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
4. WITHDRAWING CONSENT BY CANDIDATES/JOB APPLICANTS
4.1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing via email. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing via email.
4.2. Upon receipt of your written request to withdraw your consent, we may require a reasonable time (depending on the complexity of the request) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) working days of receiving it.
4.3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your job application (as the case may be). We shall, in such circumstances, notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing via email.
4.4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
5. ACCESS TO AND CORRECTION OF PERSONAL DATA
5.1. Access request to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data. We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within thirty (30) working days after receiving your request, we will inform you in writing via email within thirty (30) working days of the time by which we will be able to respond to your request. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
5.2. Correction request to correct or update any of your personal data which we hold about you. We will respond to your correction request as soon as reasonably possible. Should we not be able to correct the correction request within thirty (30) working days after receiving your request, we will inform you in writing via email on the time by which we will be able to correct your correction request.
6. PROTECTION OF PERSONAL DATA
6.1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus and firewall protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third-party service providers and agents only on a need-to-know basis.
6.2. No method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
7. ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing via email.
8. RETENTION OF PERSONAL DATA
8.1. We may retain your personal data till it fulfils the purpose for which it was collected, or as required or permitted by applicable laws.
8.2. We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
8.3. We will ensure that your personal data that no longer has any purpose or legal use will be destroyed or disposed of in a secure manner. This applies to both paper documents and electronic data stored in database.
9. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
We will comply with the Data Protection Provisions in respect of the transferred personal data while your personal data remains in its possession or control under us. We will ensure that the personal data transfer is in accordance with data protection regulations and with comparable standards.
10. EFFECT OF POLICY AND CHANGES TO POLICY
10.1. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
10.2. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
11. CONTACT INFORMATION
You may contact our Data Protection Officer if you have any questions or feedback on our personal data protection policies and procedures, or if you wish to make any request, please contact our Data Protection Officer at:
Email to: firstname.lastname@example.org or
Write in: Data Protection Officer
3 Fraser Street
#08-24, DUO Tower
For general information about PDPA, please visit the Personal Data Protection Commission’s website at http://www.pdpc.gov.sg.
Policy Last Updated on March 2021