DATA PROTECTION POLICY FOR EMPLOYEES

This Data Protection Policy (“Policy”) sets out the basis upon which Business Edge Personnel Services Pte Ltd (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of employees (“you” or “your”) in accordance with the Singapore 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.

 

This Policy is an addendum to your Employment Contract, and should be retained as part of the whole document for the employment process.

 

APPLICATION OF THIS POLICY

This Policy applies to all persons engaged in a contract of service with us (whether on a part- time, temporary or full-time basis) including interns and trainees working at or attached to us (collectively referred to as “employees”) and all references to “employment” shall apply equally to internships and traineeships (as may be applicable).

This Policy also applies to employees who are seconded to other organisations for the purposes of business arrangement.

 

PERSONAL DATA

As used in this Policy, “personal data” means data, whether true or not, about an employee 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.

 

An employee, personal data which we may collect in the context of your employment with us includes, without limitation, your:

  1. full name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country and city of birth;

  2. mailing address, mobile numbers, email address and other contact details;

  3. employment and training history;

  4. salary information and bank account details;

  5. details of your next-of-kin, emergency contact person, spouse and other family members;

  6. work-related health issues and disabilities or records on leave of absence from work;

  7. photographs and other audio-visual information;

  8. medical, performance assessments and disciplinary records; and

  9. any additional information provided to us by you voluntarily.

 

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your employment 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. 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).

 

As an employee, your personal data will be collected, used and may be disclosed to authorised third parties by us for the following purposes:

  1. performing obligations under or in connection with your contract of employment with us, including payment of remuneration and tax;

  2. all administrative and human resources related matters within our organisation, including administering payroll, granting access to our premises and computer systems, processing leave applications, appraisal, administering your insurance and other benefits, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource policies;

  3. managing and terminating our employment relationship with you, including monitoring your internet access and your use of our intranet email to investigate potential contraventions of our internal or external compliance regulations, and resolving any employment related grievances;

  4. assessing and evaluating your suitability for employment/appointment or continued employment/appointment in any position within our organisation;

  5. ensuring business continuity for our organisation in the event that your employment with us is or will be terminated;

  6. performing obligations under or in connection with the provision of our goods or services to our clients;

  7. facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organisation, or corporate restructuring process;

  8. 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;

  9. 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;

  10. ensuring security and safety;

  11. facilitating our compliance with any laws, customs and regulations which may be applicable to us; and

  12. any other incidental business purposes related to or in connection with the above.

The purposes listed in the above clauses 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 (including, where applicable, a period to enable us to enforce our rights under any contract with you).

As an employee if you provide any other’s individual personal data other than your own personal data to us, you should obtain the consent for collection, use and disclosure from the individual before disclosing the personal data to us.

 

WITHDRAWING 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 via email. You may withdraw consent and request us to stop collecting and/or using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing via email to our Data Protection Officer at the contact details provided.

 

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 to take effect your request within 10 business days after receiving the request. However, if we are unable to complete your request within the timeline, we will inform you within the 10 business days.

 

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. Should you decide to cancel your withdrawal of consent, please inform us in writing via email.

 

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 OF PERSONAL DATA

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 via email to our Data Protection Officer at the contact details provided below.

 

We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within 30 business days after receiving your access request, we will inform you in writing via email the time by which we will be able to respond to your request. If we are unable to provide you with any personal data 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).

 

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.

 

We will not provide information under the access requirement for:-

  1. opinion data kept solely for an evaluative purpose;

  2. any examination, examination scripts and, prior to the release of examination results, examination results;

  3. the personal data of the beneficiaries of a private trust kept solely for the purpose of administering the trust;

  4. personal data kept by an arbitral institution or a mediation centre solely for the purposes of arbitration or mediation proceedings administered by the arbitral institution or mediation centre;

  5. documents related to a prosecution if all proceedings related to the prosecution have not been completed;

  6. personal data subject to legal privilege;

  7. personal data which, if disclosed, would reveal confidential commercial information that could, in the opinion of a reasonable person, harm the competitive position of the organisation;

  8. personal data collected, used or disclosed without consent pursuant to the exemptions in the PDPA, for the purposes of an investigation if the investigation and associated proceedings and appeals have not been completed;

  9. the personal data was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he was appointed to act —

  • under a collective agreement under the Industrial Relations Act (Cap. 136) or by agreement between the parties to the mediation or arbitration;

  • under any written law; or

  • by a court, arbitral institution or mediation centre.

10. any request:-

  • That would unreasonably interfere with the operations of the organisation because of the repetitious or systematic nature of the requests;

  • If the burden or expense of providing access would be unreasonable to the organisation or disproportionate to the individual’s interests;

  • For information that does not exist or cannot be found;

  • For information that is trivial; and

  • That is otherwise frivolous or vexatious.

11. personal data or other information shall not be provided to an individual if the provision of that Personal Data or information could reasonably be expected to:

  • Threaten the safety or physical or mental health of an individual other than the individual who made the request;

  • Cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;

  • Reveal Personal Data about another individual;

  • Reveal the identity of an individual who has provided Personal Data about another individual and the individual providing the Personal Data does not consent to the disclosure of his/her identity; or be contrary to national interest.

 

If Personal Data has been disclosed to a prescribed law enforcement agency without the consent of the individual or pursuant to the exemptions in the PDPA, we shall not be required to inform the individual of such disclosure.

 

CORRECTION OF PERSONAL DATA

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 via email to our Data Protection Officer at the contact details provided below.

We will respond to your correction request as soon as reasonably possible. Should we not be able to correct the correction request within 30 business days after receiving your request, we will inform you in writing via email on the time by which we will be able to correct your correction request. If we are unable 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).

 

Correction requests will not be approved in respect to:

  1. opinion data kept solely for an evaluative purpose;

  2. any examination conducted by an education institution, examination scripts and, prior to the release of examination results, examination results;

  3. the personal data of the beneficiaries of a private trust kept solely for the purpose of administering the trust;

  4. personal data kept by an arbitral institution or a mediation centre solely for the purposes of arbitration or mediation proceedings administered by the arbitral institution or mediation centre; or

  5. a document related to a prosecution if all proceedings related to the prosecution have not been completed.

 

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 and firewall protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, 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 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 purposes for which they were 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 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

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 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:

 

EFFECT OF POLICY AND CHANGES TO POLICY

This Policy 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.

 

We may notify you regarding revision of this Policy from time to time. You may also determine if any such revision has taken place by referring to the date on which the policy was last updated. Your continued employment and participation in our employment constitute your acknowledgement and acceptance of such changes.

 

CONSENT CLAUSE FOR EMPLOYEES

You acknowledge that you must not, either during or after your employment, copy, extract, retain or translate any personal data for unofficial use, or allow others to do so. You cannot directly or indirectly disclose, publish or show them to the Press or to individuals in any form (e.g. electronic copy, physical copy, etc.) whatsoever, except as part of your official duties. 

 

You acknowledge that you have read and understood our Data Protection Policy and consent to the collection, use, and disclosure of your personal data by us for the purposes set out in this Policy.

 

You acknowledge that the personal data provided by you is accurate and complete.