This Data Privacy Notice (“Notice”) sets out the basis upon which Coinut Pte Ltd (“we”, “us” or “our”) may collect, use, disclose, or otherwise process the personal data of job applicants by 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 organizations in which we have engaged to collect, use, disclose, or process personal data for our purposes.
1. APPLICATION OF THIS NOTICE
1.1 This Notice applies to all persons who have applied for any such position with us (“job applicants”).
2. PERSONAL DATA
2.1 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.
2.2 Personal data which we may collect includes, without limitation, your:
- name or alias, gender, last 4 characters of your NRIC/FIN or passport number, date of birth, nationality, and country and city of birth;
- mailing address, telephone numbers, email address, and other contact details;
- resume, educational qualifications, professional qualifications and certifications, and employment references;
- employment and training history;
- work-related health issues and disabilities; and
- personality test result.
2.3 Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
3. COLLECTION, USE, AND DISCLOSURE OF PERSONAL DATA
3.1 We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your job application with us, or via a third party who you have duly authorised 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).
3.2 Your failure to supply consent or provide certain personal data to us (or if you do not permit us to process your personal data), may/would result in us being unable to process, administer and/or manage your relationship with us.
3.3 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:
- assessing and evaluating your suitability for employment in any current or prospective position within the organisation;
- verifying your identity and the accuracy of your personal details and other information provided;
- performing obligations under or in connection with your contract of employment with us, including payment of remuneration and tax;
- all administrative and human resources related matters within our organisation, including administering payroll, granting access to our premises and computer systems, processing leave applications, 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;
- 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;
- assessing and evaluating your suitability for employment/appointment or continued employment/appointment in any position within our organisation;
- performing obligations under or in connection with the provision of our goods or services to our clients; and
- facilitating our compliance with any laws, customs and regulations which may be applicable to us.
3.4 The company may request you to provide information about other individuals, such as external job referees. You hereby represent and warrant that, in providing the personal information of these individuals to the company, you have obtained their consent to share their personal data with Coinut and have secured their agreement to the collection, use, disclosure, and processing of their personal data by Coinut for the purposes specified.
3.5 We may disclose or transfer your personal data where such disclosure/transfer is required for performing obligations in the course of or in connection with our provision of services requested by you.
- In order to conduct the recruitment more smoothly, Coinut may need to disclose your personal data to third parties, whether located within or outside Singapore, for one or more of the Purposes. Such third parties include but not limited to our third party service providers, affiliates or related corporations that would be processing your personal data on Coinut's behalf.
- We will take steps to ensure that your personal data that is transferred or disclosed to third parties continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
- Except where permitted by law (and not excluding disclosures to third parties for Purposes), Coinut will not disclose your personal data to any third parties without first obtaining your consent permitting us to do so or unless any such disclosure is permitted under any of the statutory exemptions under the Act.
4. RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
4.1 In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Coinut Pte Ltd or another person. In relying on the legitimate interests exception of the PDPA, Coinut Pte Ltd will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
4.2 In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
- Storage of the personal data with trusted cloud services;
- Fraud detection and prevention;
- Network analysis to prevent fraud and financial crime, perform credit analysis; and
- Appropriateness analysis for the position.
4.3 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.
5. WITHDRAWING CONSENT
5.1 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.
5.2 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.
5.3 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).
5.4 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.
5.5 Should you wish to withdraw your personal data from Coinut, you may contact the DPO or click on the following link:
6. ACCESS TO AND CORRECTION OF PERSONAL DATA
6.1 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.
6.2 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.
6.3 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)
6.4 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.
6.5 Should you wish to access your data or make a correction, you can contact the DPO or click on the following links:
7. PROTECTION OF PERSONAL DATA
7.1 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, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, and security review and testing performed regularly.
7.2 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.
8. ACCURACY OF PERSONAL DATA
8.1 We will take reasonable and appropriate measures to ensure that the Personal Data we collect about you is accurate, complete, not misleading and kept up to date, taking into account its intended use. Where possible, we will validate the Personal Data provided by you using generally accepted practices and guidelines. If we are in an ongoing relationship with you, it is important that you update us of any changes to your business contact information.
9. RETENTION OF PERSONAL DATA
9.1 We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, used, disclosed, or as required or permitted by applicable laws.
9.2 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/used/disclosed and are no longer necessary for legal or business purposes.
10. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
10.1 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.
11. DATA PROTECTION OFFICER
11.1 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: CAI JINGLI
Email Address: dpo@coinut.com
Address: 1 Wallich St, #14-01, Guoco Tower, Singapore 078881
12. EFFECT OF NOTICE AND CHANGES TO NOTICE
12.1 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.
12.2 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.
12.3 Effective Date: 25 August 2024
(Last updated: )
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