Personal Data Protection Policy
1. Just Recruit Singapore Pte Ltd (“JR”, "us", "we", "our") is the operator of www.justrecruit.com.sg (the "Website"). We take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the "PDPA") seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
2. This Personal Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process your personal data.
3. Unless restricted by the PDPA or any other applicable law, you agree that we may process your personal data in the manner, and for the purposes set out in the terms described in paragraph 2 above.
What is Personal Data
4. Personal data means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access.
5. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.
How Personal Data is collected
6. Here are examples of situations where we collect your personal data:
(a) when you register for an account on the Website, apps or kiosks;
(b) when you apply for employment with us (by telephone, in person, snail mail or electronically);
(c) when you communicate with us directly in relation to our services (in person via our co-workers in our office, by email, telephone or any other means);
When Personal Data Collected and what is Collected
7. You can use and browse the Website without disclosing your personal data. The provision of your personal data is voluntary. But, if you do not provide your personal data to us, we may not be able to provide the services that you require of us.
8. We collect personal data through registration, completion of forms, emails, inquiries, requests, and other situations where you have chosen to provide personal data to us.
9. If you are a candidate for employment, we will collect personal data that you provide to us during the recruitment process, including personal data that is contained in your resume and in any application form that we require you to fill up. Such personal data may include your employment history and working eligibility rights.
10. Hence, subject to the aforesaid, such personal data may include:
Contact information (address, phone number, e-mail address);
Passport or identification details;
Employee identification number;
Date of birth;
Contents of any other identification provided to the Company for application or employment purposes;
Education and employment history;
Work-related skills and experience;
Professional credentials or licenses;
Membership in professional organizations;
Any other information contained on an individual’s Curriculum Vitae (CV);
Citizenship and work authorization status;
Disability, medical and health-related information;
Next-of-kin or emergency contact information;
Information from and related to publicly published profiles you’ve created on job-related social media platforms and job boards (such as LinkedIn, Monster, or Indeed);
Information provided by references; and
Information regarding your career interests, preferences, and qualifications.
11. In addition, under certain circumstances and consistent with prevailing laws, we may request types of personal data that are viewed by some countries as “sensitive”:
National identification, tax identification, passport number or social security number(s);
Credit standing, financial or bank account information;
Results of drug, criminal, and/or background screenings;
Information contained within your personnel file with the Company, such as performance reviews, disciplinary action, and other payroll related information; and
Health information, including that related to a work-related claim (e.g. workers’ compensation claim).
12. This list, however, is not exhaustive and is open to change. For example in the course of identifying suitable employment opportunities for you we may make enquiries of referees whose names you have provided to us. This information will be added to that which we already retain. We can provide a copy of your personal information which we retain should you request it. If you request us to delete your information from our database, we will do so.
Purposes for Collection, Use, Disclosure and Processing of Personal Data
13. We collect personal data if it is necessary for us to conduct our everyday activities or functions.
14. The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including:
(a) to communicate with you;
(b) to facilitate actual or possible work placement or assignments with our customers and/or act as your Employer;
(c) to administer assessment of your ongoing performance and prospects;
(d) to provide human resources related services to our customers;
(e) to establish your identity and background;
(f) to respond to your enquiries or complaints and resolve any issues and disputes which may arise in connection with any dealings with us;
(g) to provide you with services or assistance that you have requested;
(h) to maintain and update internal record keeping;
(i) for internal administrative purposes;
(j) to process and analyse your personal data either individually or collectively with other individuals;
(k) to share any of your personal data with the auditor for our internal audit and reporting purposes;
(l) to share any of your personal data pursuant to any agreement or document which you have duly entered with us for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;
(m) for audit, risk management and security purposes;
(n) for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
(o) for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
(p) to transfer or assign our rights, interests and obligations under any agreements entered into with us;
(q) for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to us;
(r) to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations;
(s) to carry out verification and background checks as part of any recruitment and selection process in connection with your application for employment with us; and/or
(t) for other purposes required to operate, maintain and better manage our business and your relationship with us which we notify you of at the time of obtaining your consent.
15. In some circumstances we may collect personal and sensitive information. This personal and sensitive information will be used in connection with your actual or possible work placement as well as our assessment of your ongoing performance and prospects. As mentioned above, this information might include:
Results of inquiries that we might make of your former employers, work colleagues, academic qualifications, professional associations or registration body;
Results of any competency or medical tests;
Performance feedback (whether positive or negative);
Additional information about you which you have provided to us.
16. As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose(s) at the time of obtaining your consent, unless we are permitted by the PDPA or any other applicable law to process your personal data without your consent.
Specific Issues for the Disclosure of Personal Data to Third Parties
17. In order to smoothly conduct our business operations or to fulfil our obligations to you, we may also disclose the personal data that you have provided to us to our client(s) for one or more of the purposes stated in or notified to you under the Purposes for Collection, Use, Disclosure and Processing of Personal Data section. We will also disclose your personal data to government regulators or authorities in order to comply with any laws, rules, guidelines, regulations or schemes that apply to us.
18. Examples of third parties that we disclose your personal data to include:
Potential and actual employers and clients (or third party organisations) of Just Recruit Singapore Pte Ltd;
Other staff at Just Recruit Singapore Pte Ltd in connection with possible employment opportunities;
Any person or body with a lawful entitlement to obtain information (whether of Singapore or a non-Singapore country);
19. The third parties whom we conduct business are only authorized to use your information to perform the service for which they were hired. As part of our agreement with them, they are required to adhere to the PDPA and any policies that we provide, and to take reasonable measures to ensure your personal data is secure.
20. We respect the confidentiality of the personal data that you provide to us. We do not sell personal data to any third party.
Request for Access and/or Correction of Personal Data
21. You may request to access and/or correct your personal data that is in our possession or under our control by writing to us at firstname.lastname@example.org
22. For a request to access personal data, we will provide you with the relevant personal data within thirty (30) days from such a request being made.
23. Where a request cannot be complied with within the above time frame, we will inform you of the reasonably soonest time in which we will respond.
24. For a request to correct personal data, we will:
(a) correct your personal data as soon as practicable after the request has been made unless we have reasonable grounds not to do so; and
(b) subject to paragraph 25 below, we will send the corrected personal data to every other organisation to which the personal data was disclosed by us within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
25. We may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
26. Depending on the scope and nature of the work required to process your access request, we may be required to impose a fee to recover our administrative costs. This will be assessed on a case-by-case basis by our Data Protection Officer. Where such a fee is to be imposed, we will provide you with a written estimate of the fee for your consideration. Please note that we will only process your request once you have agreed to the payment of the fee. In certain cases, we may also require a deposit from you before we process the access request. You will be notified if a deposit is required when we provide you with the written estimate of the fee, if any.
27. You understand that we are reliant on you to provide us with accurate and complete personal data and with updates if there are any changes to your personal data. We will not be responsible for relying or using any inaccurate or incomplete personal data where you have provided with such personal data and/or have failed to update us of any changes in your personal data.
Request to Withdraw Consent
28. You may withdraw your consent for the collection, use and/or disclosure of your personal data that is in our possession or under our control by writing to us at email@example.com.
29. We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
30. Your withdrawal of consent may result in certain consequences. For example, it may mean that we will not be able to provide you with the services that you have requested or that we will not be able to continue with your existing relationship with us. We will inform you of such consequences after we receive your request for withdrawal.
31. However, you understand that notwithstanding your withdrawal of consent, we will still be entitled to collect, use or disclose your personal data if we are required or authorised to do so under the PDPA or any other applicable law.
Protection and Destruction of Personal Data
32. We will put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. In particular, reasonable security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
33. We will also put in place measures to ensure that any of your personal data that is in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that:
the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and
retention is no longer necessary for any other legal or business purposes.
34. If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us by writing to us at firstname.lastname@example.org.
35. We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
36. You may contact us (or send us any request or complaint form) either by post or by email at the following address:
Data Protection Officer
Just Recruit Singapore Pte Ltd
18 Howard Road #09-11
Contact No.: 65-6222 2426
EA Licence Number: 12C6295
Email Address: email@example.com
Updates on Personal Data Protection Policy
37. As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
38. We reserve the right to amend the terms of this Personal Data Protection Policy at our absolute discretion. Any amended Personal Data Protection Policy will be posted on the Website and can be viewed at www.justrecruit.com.sg. No individual notice will be sent to you.
39. You are deemed to have acknowledged and agreed to any amended version of this Personal Data Protection Policy if you continue to use the Website after the changes have taken place. As such, you are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
Last Updated on 03 Jan 2020
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