This Data Protection Notice (“Notice”) sets out the basis which R. Andersen & Partners Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data in accordance with the Personal Data Protection Act (“PDPA”). This Notice 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.
By accessing our websites and/or submitting your personal information to us through any means, you consent to the use and disclosure of your information as set out in the Policy.
As used in this Notice:
“personal data” means data, whether true or not, about an individual 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.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include, but not limited to name, email address, telephone number, nationality, employment information, educational/ professional qualifications and renumeration and any other information relating to any individuals which you have provided to us, or via other forms of interaction with you.
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
We may collect your personal data when:
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;
you provide any data in connection with your interest to be our candidate for career opportunities or application for any job opportunities through us;
you are contacted by, and responds to, our employees
we receive references about you from our business partners and third parties;
it is available from public sources;
collection and use of personal data without consent is permitted or required by the PDPA or other laws. 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).
Under clause 5a and 5b (i) of MOM's Employment Agencies Licence Conditions, we are required to collect the NRIC/FIN or passport numbers of applicants referred to our clients for permanent or contract job positions of at least six months with a fixed monthly salary of $3,300 and above. As it is a regulatory requirement, we are permitted to collect, use and disclose a candidate’s NRIC/FIN or passport number for this purpose. This information will not be provided to our clients, but submitted to the MOM. Please refer to A13 and 14 of MOM’s FAQs on fair recruitment for more information on this requirement.
As a general rule and in support of the Tripartite Alliance for Fair and Progressive Hiring Practices (TAFEP), we do not collect information relating to a candidate’s age, gender, race, religion, marital status and family responsibilities or disability.
Information Collected on Website:
Users are advised that there are inherent risks in transmitting information across the internet. The Internet is an open system and we cannot guarantee that the personal information you submit will not be intercepted by others. Our websites may include links to external websites operated by other organisations. They may collect personal information from visitors to their site. We cannot guarantee the content or privacy practices of any external websites and do not accept responsibility for those websites.
When you access our website, we gather information about users collectively. Such information includes the areas that users visit most frequently and the services users access the most. We will only use such data anonymously and in the aggregate. By doing so, we can optimise the services it provides to you.
We may collect and use your personal data for any or all of the following purposes:
performing obligations in the course of or in connection with our provision of the services to you;
verifying your identity;
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;
transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
any other incidental business purposes related to or in connection with the above.
We may disclose your personal data:
where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you;
analytics and tracking purposes; or
to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us 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 your Consent
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.
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 your request within ten (10) business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
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 and Correction of Personal Data
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 about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
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.
We will respond to your request as soon as reasonably possible. In general, our response will be within ten (10) business days. Should we not be able to respond to your request within thirty (30) days after receiving your 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).
Protection of Personal Data
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, encryption, and disclosing personal data both internally and to our authorised third-party service providers and agents only on a need-to-know basis.
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
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
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
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.
Transfer of Personal Data Outside of Singapore
We generally 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 we 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
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:
Contact No.: 6632 3495
Email Address: email@example.com
Effects of Notice and Changes to Notice
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.
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.
Updated in March 2021