DATA PROTECTION NOTICE FOR JOB APPLICANTS

This Data Protection Notice (“Notice”) sets out the basis upon which Konexo Singapore Pte. Ltd. (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of job applicants 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 purposes.

APPLICATION OF THIS NOTICE

1. This Notice applies to all persons who have applied for any part-time, temporary or full-time position with us including interns and trainees, as well as service providers who wish to enter into a contract for services for the provision of services to us or our clients (collectively referred to as “job applicants”).

PERSONAL DATA

2. As used in this Notice, “personal data” means data, whether true or not, about a job applicant who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

3. Personal data which we may collect includes, without limitation, your:

• (a) Name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country and city of birth
• (b) Mailing address, telephone numbers, email address and other contact details;
• (c) Resume, educational qualifications, professional qualifications and certifications and employment references;
• (d) Employment and training history;
• (e) Salary information;
• (f) Details of your next-of-kin, spouse and other family members;
• (g) Work-related health issues and disabilities;
• (h) Access logs and usage records from our systems including electronic access systems and other security control systems; and
• (i) Photographs and other audio-visual information.

4. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION OF PERSONAL DATA

5. We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your employment or job application with us, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, which may include your job placement agent), 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 (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws.

6. By providing us with any personal data relating to a third party (including but not limited to information about your family members), you represent to us that you have validly obtained the consent of the third party to provide us with their personal data for the respective purposes below

7. 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).

USE OF PERSONAL DATA

8. Your personal data will be collected and used by us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:

• (a) Assessing and evaluating your suitability for employment in any current or prospective position within the organisation;
• (b) Verifying your identity and the accuracy of your personal details and other information provided;
• (c) Performing obligations under or in connection with the provision of our services to our clients;
• (d) Facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organisation, or corporate restructuring process; and
• (e) Facilitating our compliance with any laws, customs and regulations which may be applicable to us.

DISCLOSURE OF PERSONAL DATA

9. We may also disclose your personal data to any:-

• (a) Person to whom we are compelled or required to do so under law or in response to a competent regulatory or government agency;
• (b) Government agencies, statutory authorities and industry regulators;
• (c) Other Konexo Entities, our parent company Eversheds Sunderland (International) LLP and members of the Eversheds Sunderland network of firms;
• (d) External advisors and other professional advisors, such as lawyers, auditors, tax consultants, accountants, insurers and other financial or professional advisors;
• (e) Banks and financial institutions; and
• (f) Any other party that we deem necessary for the purposes as outlined in paragraph 6 above.

10. The purposes listed in the above paragraphs may continue to apply even in situations where your relationship with us (for example, if we decide not to hire you or pursuant to your employment contract should you be hired) 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 a contract with you).

WITHDRAWING CONSENT

11. 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. As a job applicant, you may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

12. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) 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 and effect your request within ten (10) days of receiving it.

13. 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 in the manner described in paragraph 11 above.

14. Please note that depending on the personal data concerned, the withdrawal of your consent may affect our ability to consider you application or engagement with us. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

15. If you wish to make (a) an access request for access 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, or (b) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

16. 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.

17. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your access request within thirty (30) days after receiving your access request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

18. Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.

PROTECTION OF PERSONAL DATA

19. 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 protection and disclosing personal data both internally and to our authorised third party service providers, agents and others only on a need-to-know basis.

20. You should be aware, however, that 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.

 

ACCURACY OF PERSONAL DATA

21. 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 or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

22. We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.

23. 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 purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

 

24. We operate globally and where we consider it necessary and appropriate, we may transfer your personal data to other Konexo Entities, our parent company Eversheds Sutherland (International) LLP, members of the Eversheds Sutherland network of firms or to a third party service or product providers within or outside Singapore for the performance of the purposes set out in paragraph 5 above, under conditions of confidentiality and similar levels of security safeguards. We may also in limited circumstances share your personal data with government authorities or others as required to protect our business interest or others, as necessary or as required by applicable law or court order.

25. Konexo is the name and brand under which the Konexo Entities provide legal or other services to clients around the world. For more information on the Konexo Entities and their relationship with Eversheds Sutherland, a global provider of legal services, please click here.

DATA PROTECTION OFFICER

26. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures; or if you wish to make any request, in the following manner:

Name of DPO : Joan Oh

Contact No. : +65 87981588

Email Address : enquiries@konexoglobal.sg

 

EFFECT OF NOTICE AND CHANGES TO NOTICE

27. This Notice applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

28. 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 employment and participation in our recruitment process constitute your acknowledgement and acceptance of such changes.

Effective date : 01/10/2020
Last updated : 01/10/2020