WEBSITE DATA PROTECTION NOTICE
This Data Protection Notice (“Notice”) sets out the basis upon which Grace Management & Consultancy Services 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 as a job applicant with us, visitor, customer, employee and general public.
2. As used in this Notice, “personal data” means data, whether true or not, about an employee or 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:
- Full Name (as per NRIC)
- Contact number
- Company’s name
4. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
5. We generally collect personal data that a) is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”) after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes, (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws, or (c) CCTV images of you are recorded for the purpose of crime prevention and personal safety. 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).
6. Generally, we collect personal data in the following ways:
- when you submit any form, including but not limited to application and registration forms or other forms relating to any of our Products or Services;
- when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our Products and Services;
- when you interact with our staff, including customer service officers, for example, via telephone calls (which may be recorded), letters, face-to-face meetings, social media platforms and emails;
- when you use our electronic services, or interact with us via our websites, and apps or use services on our websites;
- when you request that we contact you or request that you be included in an email or other mailing list;
- when you submit an employment application or when you provide documents or information including your resume and/or CVs in connection with any appointment or any other position.
- when your images are captured by us via CCTV cameras or face recognition system while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises;
- when you are contacted by, and respond to, our marketing representatives and customer service officers.
- when we receive references from business partners and third parties, for example, where you have been referred by them with your consent.
- when we seek information from third parties about you and receive your Personal Data in connection with your relationship with us, including for our Products and Services or job applications, for example, from business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities; and/or
- when you submit your Personal Data to us for any other reasons.
7. Third Parties: If you are submitting Personal Data of another individual to us, you should ensure that all Personal Data submitted is complete, accurate, true and correct, and all necessary consents are obtained and/or have provided any required notices to these individuals. Alternatively, you may provide Personal Data to us if you have another legal justification to provide us such information so that we can use it for the purposes and on the bases set out in this Notice.
8. If you provide us with personal data of another person, you represent and warrant to us that you have been appointed and authorized by the other person to act on his behalf. This includes providing consent to our collection, use, disclosure, transfer and retention of his personal information and sensitive personal information.
9. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested, or delays in processing your applications.
10. However, when you voluntarily provide personal data to us for a purpose and it is reasonable that you do so we may rely on you being deemed to have consented to us collecting, using and disclosing your personal data for that purpose.
11. Under certain circumstances, we may collect, use and/or disclose personal data about you without your consent for example, so that we can comply with our statutory obligations or where personal data is publicly available.
12. 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:
- performing obligations in the course of or in connection with our provision of services requested by you ;
- in the event of contact tracing;
- verifying your identity and security;
- employment and job application;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- managing your relationship with us;
- complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
- any other purposes for which you have provided the information;
- any other incidental business purposes related to or in connection with the above.
13. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, 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).
14. After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes.
15. When and if there’s new need and purpose to use and disclose your personal information to any organisation that’s not related to any employment purposes and outside the Company, the HR/Admin team will request for your consent, and you will be notify on the purpose of use or disclosure of your personal data with the Company, you will also be notify the consequences of refusal to give your consent.
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
16. In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Grace Management & Consultancy Services Pte Ltd or another person. In relying on the legitimate interests exception of the PDPA, Grace Management & Consultancy Services will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
17. In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
- Fraud detection and prevention;
- Detection and prevention of misuse of services;
- Network analysis to prevent fraud and financial crime, and perform credit analysis; and
- Collection and use of personal data on company-issued devices to prevent data loss.
- Business Improvement such as enhancing or developing new good or services
- Enhancing and developing new processes for business operations
- Conduct of broader research and development that may not have immediate application to our services or business operations
- To respond to an emergency that threatens the life, health and safety of individual.
18. The purposes listed in the above clause 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.
WITHOLDING OF CONSENT
19. You are entitled under applicable law to withhold consent to the collection, use or disclosure of personal data, and Grace Management & Consultancy Services will respect your choices in this regard. You may withhold consent at any juncture that you are asked for consent.
20. However, as recognised by and provided for under the PDPA, it may be that any choice you make to withhold consent may impact our ability to proceed with your transactions or interactions with us.
21. Grace Management & Consultancy Services will take the approach that best safeguards us, you and others from risks, and we may well have no choice but to decline to proceed with the transaction or interaction in question to avoid causing harm or exposing us, you or others to risk.
22. At the same time, it should be noted that your withholding of consent will not prevent us from exercising our legal rights (including any remedies, or undertaking any steps as we may be entitled to at law).
23. 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. 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.
24. 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 fourteen (14) days of receiving it.
25. 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 request. We shall, in such circumstances, notify you before completing the processing of your request of withdrawal. Should you decide to cancel your withdrawal of consent, please inform us in writing via email.
26. 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.
ACCESS TO PERSONAL DATA
27. If you wish to make 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, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
28. 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.
29. 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).
30. In the event an access request is rejected, and if you are dissatisfied with the organisation refusal to access the data – you may write to our Data Protection Officer again to highlight your objection and our Data Protection Officer will escalate to higher management to review the decision and ground to reject your request. Our Data Protection Officer will endeavour to revert to you within thirty (30) days.
31. 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.
CORRECTION TO PERSONAL DATA
32. If you wish to make 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.
33. We will respond to your request as soon as reasonably possible. In general, our response will be within fourteen (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).
34. In the event a correction request is rejected, and if you are dissatisfied with the organisation refusal to correct the data – you may write to our Data Protection Officer again to highlight your objection and our Data Protection Officer will escalate to higher management to review the decision and ground to reject your request. Our Data Protection Officer will endeavour to revert to you within thirty (30) days.
35. 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.
36. Once correction to personal data is done, organisation will communicate the corrections to third parties whom the personal data was disclosed.
PROTECTION OF PERSONAL DATA
37. 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 minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, and security review and testing performed regularly.
38. 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
39. 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
40. 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.
41. 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
42. We do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
DATA PROTECTION OFFICER
43. You may contact our Data Protection Officer if you have any enquiries or feedback, complain and dispute on our personal data protection policies and procedures; or if you wish to make any request, in the following manner:
Name of DPO: Data Protection Officer
Contact No. : +65 6296 4333
Email Address: firstname.lastname@example.org
EFFECT OF NOTICE AND CHANGES TO NOTICE
44. 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.
45. 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.
Last updated: 13 March 2023