Notice and Choice Principles

We hope this Notice gives you a good understanding on how we handle employees’/ potential employees’ personal data that we collect, process and store in the Company and/or its subsidiaries/ associate companies/ related companies/ entities, whether related or associated now or at a future date. This document is also intended to give you, as a data subject, knowledge on how you can control our disclosure of such data.

We are processing your personal data

The Company needs to collect and process your personal data in order to generally perform the Employment Contract / potential Employment Contract to which you are/ maybe a party to whether it is pursuant to an Employment Contract directly with the Company or with any of the Company’s clients who use our services to secure candidates for potential employment with them.

Generally, your personal data that we collect and process include:
Name, identification number, passport number, statutory information, Income Tax /Social Security/Employee Provident Fund numbers, address, contact numbers, gender, date of birth, family information, education, personal email address, photo, nationality, languages, hobbies and interest, previous employers data, salary, bank account numbers and vehicles information.

Sensitive Data

Some of the personal data that we collect and process may include what is defined as ‘sensitive personal data’ and these include, but not restricted to: Race, Religion, Health, Political opinion, Records of criminal offence

How do we use your data?

Generally, the Company will be using your personal data to discharge its obligations as your Employer/ potential Employer and/or for purposes of securing suitable employment with any of the Company’s clients who use our services to secure candidates for potential employment with them. Specifically, the purpose for which your personal data may be used and further processed includes, but not restricted to, the following:-

In respect to your employment and/ or securing direct employment with the Company

• For assessment of your job application to the Company;
• For administration purposes related to employment;
• For the purposes of our corporate governance;
• For all other purposes in relation to or incidental to performing the

Employment Contract such as:

1. Payroll,
2. Medical Benefits/ Insurance coverage,
3. Training needs analysis,
4. Restructuring exercises including promotions, demotions, transfers, secondments, etc,
5. Disciplinary action,
6. Performance Management,
7. Any other employment related purposes.

In respect to securing employment with any of the Company’s clients

• For assessment of your suitability as a candidate. The assessment may be undertaken by the Company and/or any of its clients
• For administration purposes related to employment with any of the Company’s clients
• For the purposes of our corporate governance;
• For all other purposes in relation to or incidental to offering you an employment opportunity from any of the Company’s clients

How is your data collected?

Most, if not all, of your personal data was obtained from you, either from the following sources or from any other information you provided:

• Resume;
• Application Form;
• Personal Particulars Form;
• Related Certificates;
• Past Training Certificates.

In some instances, your personal data may have been obtained from external sources including, but not restricted to the following:

• Reference Checks / Verification Source (personal or private);
• Third party service providers and any other future third parties in relation or incidental to the above.

To whom we may disclose your information

Your personal data will be kept confidential but it may be provided or disclosed to third parties for the purposes stated above. Whilst we do not disclose your information to any third parties unless it is within the ambit of permitted disclosures under prevailing laws/guidelines and/or you have consented to such disclosure, we may disclose your information to the categories of parties as listed below (not restricted to) :

• Third party service providers and any other future third parties that we may contract with;
• Third party service providers for the purposes of performing reference checks, background screening, bankruptcy searches, criminal records;
• The company’s appointed medical practitioner(s);
• Statutory bodies such as Employee Provident Fund, Social Security, Income Tax, Human Resource Development Fund
• Professional advisors including lawyers, accountants, auditors, insurers & brokers on a need to know basis for the purposes of providing their services/advices to us;
• Agent or contractors acting on our behalf or appointed by us to act on our behalf for purposes of performing a contract of employment.

We will ensure that reasonable steps are taken by the above categories of parties to protect or maintain confidentiality of your information that we may disclose to them.

Limiting the processing of personal data

Although, as stated above, we only process your personal data for purposes stated above, in the event, your personal data is being processed for other purposes (with your consent), you have a right to request us to stop such processing. You may exercise this right by contacting us. This right extends to stopping the processing of your personal data which relates to the personal data of other persons.

Provision of Information

As an employee/ job applicant (whether applying for a job with the Company or any of its clients), you have the right to decide what information that you wish to provide. However, please be informed that all the information that we request for, as stated above, are mandatory information for us. If you choose not to provide and/or fail to supply us with such personal data, we will not be able to perform the Contract of Employment/ offer you employment whether directly with the Company or with any of the Company’s clients. Accordingly, if you decide not to provide the mandatory information to us, it may necessarily mean that (I) your Contract of Employment with the Company will have to be terminated or (ii) that an offer of employment with the Company will not be made or (iii) you will not be considered for an offer of employment by any of the Company’s clients.

The Company reserves the right to review and/or amend this Notice from time to time and will communicate such changes along with the updated Policy on the Company’s website, and/or other appropriate communication means as may be determined by the Company.