This Data Protection Notice (“Notice”) sets out the basis upon which Koru Partners Pte Ltd (“KORU”, “we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of job applicants in accordance with the Singapore Personal Data Protection Act (“PDPA”) and all associated regulations and guidelines which may from time to time be issued by the Personal Data Protection Commission (PDPC) of Singapore. 

APPLICATION OF THIS NOTICE 

1. This Notice concerns all persons who have applied for any such position with us (referred to as “job applicants”). 

2. This Notice applies to personal data of all persons described above which are 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. 

TYPES OF PERSONAL DATA WE COLLECT 

3. As used in this Notice, “personal data” means data, whether true or not, about 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. 

4. Personal data which we may collect includes, without limitation, your: 

• name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country of birth; 
• residential address, telephone numbers, email address and other contact details; 

• immigration status, e.g. Singapore Citizen, Singapore Permanent Resident, Long Term Visit Pass, Work Permit etc.; 

• resume, educational qualifications, professional qualifications and certifications and employment references; 

• employment and training history; and 

• social media accounts, e.g. LinkedIn, Github, Instagram etc. [optional and subject to job applicant’s discretion]. 

5. 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 

6. 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 has been duly authorized by you to disclose your personal data to us (your “authorized representative”, which may include your job placement agent),  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 use 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 authorized by law). 

7. You have choices regarding our collection, use or disclosure of your personal data. If you choose not to provide us with the personal data described in this notice, we may not be able to process your job application. You have the right to object to the processing of your personal data and withdraw your consent in the manner described in Section 10 below. However, we may collect, disclose, or use your personal data pursuant to an exception under the PDPA or other written law, including but not limited to:  

• it is necessary for any purpose which is clearly in the interests of the individual, and: 

• consent for the collection, use, or disclosure cannot be obtained in a timely way; or 

• the individual would not reasonably be expected to withhold consent; 

• it is publicly available; 

• it is in the national interest; and 

• it is in the legitimate interests of the organization or another person, and the legitimate interests of the organization or other person outweigh any adverse effect on the individual. 

8. 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 KORU; and 

• verifying your identity and the accuracy of your personal details and other information provided 

Furthermore, if you choose to share personal data of other people (such as your references and emergency contact) with us, it is your responsibility to inform such other people, whose personal data you provide, about the use of their personal data as set out in this Notice. 

9. The purposes listed above 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).

WITHDRAWING CONSENT 

10. 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. As a job applicant, you may withdraw consent and request for us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by writing to us at the contact details provided in Section 29. 

11. 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. Should we require more time to give effect to a withdrawal notice, we will inform you of the time frame by which the withdrawal of consent will take effect. 

12. 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 able to process your job application. We shall, in such circumstances, notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 10 above. 

13. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws. 

ACCESS TO AND CORRECTION OF PERSONAL DATA 

14. 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 in Section 29.  

15. Before we accede to your access or correction request, we will need to verify your identity by checking identification document, and the legitimacy of your request. Please do 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. 

16. 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. We are not obliged to provide you with access to records or decisions that KORU has created for evaluative purposes.  

17. We will respond to your access or correction request as soon as reasonably possible, or within thirty (30) calendar days from the date we receive your request. If we are unable to do so within 30 calendar days, we will let you know and give you an estimate of how much longer we require. 

PROTECTION OF PERSONAL DATA 

18. To safeguard your personal data from unauthorized 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, access control, password protection etc. 

19. When we disclose your personal data to third parties in line with the purposes mentioned in Section 8, we will ensure that they provide sufficient guarantees to us to have implemented the necessary security measures to protect your personal data. 

20. 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 

21. We generally rely on personal data provided by you. It is your responsibility to ensure, to the best of your knowledge, that the personal data you provide us with are accurate, complete, and up to date. 

22. 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 in Section 29. 

RETENTION OF PERSONAL DATA 

23. 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. 

24. 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. 

25. We dispose of or destroy such documents containing your personal data in a secure manner when the retention limit is reached, and it is reasonable to assume that the permitted purpose is no longer being served by their retention. 

26. For unsuccessful job applicants, records will be kept from immediate up to 2 years for possible re-engagements, after which the records will be disposed. The records will be disposed of in a secure manner immediately after the said retention period. You may contact our DPO in the contact details provided below for any request of information about the duration and the purposes for which your personal data is retained and how we will destroy your personal data once the retention period is over. 

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE 

27. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, 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, including entering into an agreement with the receiving party to accord similar levels of data protection as those in Singapore. 

DATA BREACH NOTIFICATION 

28. In the event of a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, we shall promptly assess the impact and if appropriate report this breach within 3 calendar days to the Personal Data Protection Commission (PDPC). We will notify you when the data breach is likely to result in significant harm to you after our notification to PDPC. We may also notify other relevant regulatory agencies, where required. 

CONTACTING US 

29. If you have any questions or feedback regarding this Notice, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) via this email address: [email protected]  

Any query or complaint should include, at least, your name and contact information. 

We treat such queries and feedback seriously and will deal with them confidentially and within reasonable time. 

EFFECT OF NOTICE AND CHANGES TO NOTICE 

30. 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. 

31. 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. 

32. Your continued participation in our recruitment process constitutes your acknowledgement and acceptance of such changes. 

Last Updated: 25 September 2024