Privacy Policy – Corporate Services Division
Privacy Policy
This Notice applies to you only if you are located or residing in the European UnionDR Consultancy Services Pte Ltd (collectively “DRC”)Effective Date 25 May 2018This Privacy Notice explains how DRC collects, uses and discloses your personal data, and your rights in relation to the personal data it holds.DRC (in this Privacy Notice, “us”, “we” and “our”) is the data controller of your personal data and is subject to the EU General Data Protection Regulation 2016/679 (the “GDPR”).Our Privacy and Data Compliance Officer is contactable by email at Privacyofficer@drc.sgThis Privacy Notice supersedes any previous Privacy Notice or equivalent which you may have been provided with or seen prior to the Effective Date stated above.Your rightsUnder the GDPR you have the following rights:
To obtain access to, and copies of, the personal data that we hold about you;
To require that we cease processing your personal data if the processing is causing you damage or distress;
To require us not to send you marketing communications;
To require us to erase your personal data;
To require us to restrict our data processing activities;
To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
To require us to correct the personal data we hold about you if it is incorrect.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.You can find out more about your rights at https://www.eugdpr.org/If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact us using the following:By post – Attention: DR Consultancy Services Pte. Ltd., Singapore Land Tower #30-00, Singapore 048623.By email – Privacyofficer@drc.sgBy telephone – +65 8333 6404If you are not satisfied with how we are processing your personal data, you can make a complaint to https://www.eugdpr.org/How we collect your dataWe collect your personal data in a number of ways, for example:
From the information you provide to us when you meet us;
From information about you provided to us by your company or an intermediary;
When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
When you complete (or we complete on your behalf) client on-boarding or application or other forms;
From your agents, representatives, advisers, intermediaries, and custodians of your assets;
From publicly available sources or from third parties, most commonly where we need to conduct background checks about you.
The categories of personal data we collectWe collect the following categories of personal data about you:
Your name and contact information such as your home or business address, email address and telephone number;
Biographical information which may confirm your identity including your date of birth, tax identification number and your passport number or national identity card details, country of domicile and/or your nationality, country of tax residency;
Information relating to your financial situation such as income, expenditure, assets and liabilities, sources of wealth, as well as your bank account details;
Information about your knowledge and work experience;
An understanding of your goals and objectives in procuring our services;
Information about your employment/business, education, family or personal circumstances, and interests, where relevant; and
Information to assess whether you may represent a politically exposed person or money laundering risk.
The basis for processing your personal data (other than with your consent), how we use that personal data and whom we share it with(i) Performance of a contract with youWe process your personal data because it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.In this respect, we use your personal data for the following:
Our data storage providers
Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you;
Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
Third parties whom we engage to assist in delivering the services to you;
Your agents, advisers, intermediaries, and custodians of your assets who you tell us about;
For any other purpose for which you provide us with your personal data. In this respect, we may share your personal data with or transfer it to the following:
To deal with any complaints or feedback you may have;
To provide you with the services as set out in our Terms of Engagement with you or as otherwise agreed with you from time to time;
To prepare a proposal for you regarding the services we offer;
(ii) Legitimate interestsWe also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person.In this respect, we use your personal data for the following:
For marketing to you. In this respect, see the separate section on Marketing below;
Training our staff or monitoring their performance;
For the administration and management of our business, including recovering money you owe to us, and archiving or statistical analysis;
Seeking advice on our rights and obligations, such as where we require our own legal advice;
In this respect we will share your personal data with the following:
Our advisers or agents where it is necessary for us to obtain their advice or assistance;
With third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.
(iii) Legal obligationsWe also process your personal data for our compliance with a legal obligation which we are under. In this respect, we will use your personal data for the following:
To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws;
As required by tax authorities or any competent court or legal authority. In this respect, we will share your personal data with the following:
Our advisers where it is necessary for us to obtain their advice or assistance;
Our auditors where it is necessary as part of their auditing functions;
With third parties who assist us in conducting background checks;
With relevant regulators or law enforcement agencies where we are required to do so.
MarketingWe will send you marketing about similar services we provide, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you.We will communicate this to you in a number of ways including by post, telephone, email, SMS or other digital channels.If you object to receiving marketing from us at anytime, please contact us:
By post – Attention: DR Consultancy Services Pte. Ltd., Singapore Land Tower #30-00, Singapore 048623.
By email – Privacyofficer@drc.sgRetention of your dataWe will only retain your personal data for as long as we have a lawful reason to do so. In particular:
where we have collected your personal data as required by anti-money laundering legislation, including for identification, screening and reporting, we will retain that personal data for five years after the termination of our relationship, unless we are required to retain this information by law or for the purposes of court proceedings; or
otherwise, we will in most cases retain your personal data for a period of seven years after the termination of our contractual or other relationship with you in case any claims arise out of the provision of our services to you.
Privacy Policy – Recruitment Division
DR Consultancy Services Pte Ltd (“DRC”) is committed to protecting your privacy and the confidentiality of any personal data provided by you, in accordance with our obligations under applicable data protection laws and best practices.By disclosing any personal data to DRC, you are consenting (without limitation or qualification) to the use and disclosure of such data in accordance with this privacy policy. Therefore please read it carefully. If you do not consent to any of the terms and conditions of this privacy policy, please do not disclose any personal data to us in any form.
What is personal data?’Personal data’ means data, whether true or not, about an individual who can be identified from that data, or other data which we have, or are likely to have access to.Personal data that we may collect includes:
your name;
telephone number;
e-mail address;
postal address;
details of your employment history;
professional and/or educational qualifications;
salary details (current and/or historical);
language proficiency;
citizenship and/or residency status;
marital status;
and other such information that may be obtainable from your resume, or online application.How do we collect it?Personal data may be collected by us through our website www.drc.sg, by e-mail correspondence, by postal mail or fax, or in person (by providing such personal data to our recruitment consultants in written form or verbally). We may also obtain personal data relating to you from publicly available sources such as third party websites, blogs, forums, social media sites and professional networking sites.Use of your personal dataPersonal data collected by us will be primarily used for providing you with recruitment services. This means that such personal data may be reviewed and analysed by us for suitability for any particular roles you have applied (or wish to apply) for, or provide you with job matching services by evaluating your suitability for and informing you (using your contact information) of, other roles that we may become aware of from time to time, or for verification of information.In addition, we may also use your personal data:
to provide you with career management or guidance services;
to allow us to process and respond to any inquiries or feedback from you;
to inform you of any events, industry updates or market developments, or other information we consider useful to you (such information will be sent by post/e-mail, texts or similar communication, and will also contain instructions for unsubscribing);
for us to carry out market research and/or market analysis (see below on the permitted disclosures of such market research and/or market analysis carried out by us);
to generate internal reports; and/or
to generally assist us to manage our relationship with you, or to provide or manage the recruitment and/or HR services we provide, including carrying out of administrative or operational tasks.
How do we disclose your data?To the extent possible we aim to minimise disclosure of your personal data to third parties.However in order to provide our services to you, and/or to effectively carry out our business, and/or to meet our legal obligations, we need to make certain disclosures from time to time. The ways in which we ordinarily disclose your personal data would be:
disclosures to prospective employers, when you apply for any specific roles, or otherwise agree that we may disclose it;
by contacting third parties (including nominated referees) to verify your educational or professional qualifications, work experience, or other such information submitted by you when obtaining our services;
by preparing and providing aggregated statistical reports on our candidates and/or website users/visitors, to our clients or proposed employer-clients, for marketing or feedback purposes. Such reports (except where consent is specifically obtained) would not include names or contact details of candidates and/or website users/visitors, and would be formatted to ensure your anonymity;
disclosures to our professional advisors (such as lawyers, accountants and financial advisors), to the extent necessary and only if they are bound to keep your personal data confidential;
as part of a proposed sale, merger, acquisition, joint venture, or transfer of assets, subject to ensuring that the recipient is under suitable confidentiality obligations in respect of your personal data and uses it only for the purposes you have agreed to and as permitted by this privacy policy;
disclosures required by law, of if requested by a government entity, or to prevent crime, or to ensure the rights, property and/or personal safety of DRC (including its officers, employees, contractors and/or agents);
as otherwise permitted by applicable law.
How is your personal data secured?Any personal data held by or on our behalf is stored on secure servers and with modern security measures in place to protect against the loss, unauthorised access or alteration, or misuse of such information. Where such personal data is held by unrelated third parties on our behalf, we have also imposed contractual obligations on such parties to ensure the confidentiality and security of such information.However while we will take all reasonable measures (as required by applicable law) to protect the integrity of such information, we cannot guarantee that loss, unauthorised access or alterations or misuse will not occur.Accuracy, validity and retention of dataWe will periodically review the personal data held by us to ensure that is accurate and up to date. We will also retain your personal data only for so long as it is necessary to provide our services to you (subject only to our internal policies on data retention, or applicable laws and regulations).It is your duty to let us know of any changes to personal data provided by you, including contact details. You can do this by contacting your designated DRC recruitment consultant directly, or by contacting us via the following:By post: 50 Raffles Place #30-00 Singapore Land Tower Singapore 048623By e-mail: Privacyofficer@drc.sgRights of accessYou may, by written request, seek reasonable access to your personal data held by us, as well as the ways in which we have used such personal data within a year of the date of the request. We will endeavour to disclose such personal data in accordance with our legal obligations, and where we refuse access we will, where possible, provide you with reasons for doing so.Any request for access must include sufficient details to identify you and the nature of your request, and be addressed to our Data Protection Officer using the following contact details:By post: 50 Raffles Place #30-00 Singapore Land Tower Singapore 048623By e-mail: Privacyofficer@drc.sgUpon receipt of your request, we may request for additional information from you (including proof of identity) in order to process your request. Please note that it may also take some time to process the application, although we aim to process all requests as soon as possible. We may also charge a reasonable fee to cover our administration costs when dealing with any requests for access, which we will inform you of in advance.Complaints and queriesIf you believe your rights under this privacy policy, or otherwise under law, have been breached, as a first recourse you must contact our Data Protection Officer in writing (using the contact details provided above), setting out sufficient details of your grievance, the affected personal data and contact details.Upon receipt of your complaint, we will carry out an internal investigation and may contact you during this period for further information. Subject to your timely cooperation, we generally endeavour to provide a formal response setting out the results of our investigation and whether we agree that your rights have been breached, within [30] days of receiving your complaint.If you are not satisfied with our response, you have the right to contact the Personal Data Protection Commission, or exercise any of your other rights in law.Revisions and governing lawWe may update this privacy policy from time to time, in accordance with our internal policies, technological developments, industry practices, applicable laws and regulations. If we make any changes to our privacy policy, we will post the revised version here, so do review it frequently. If significant changes are made, we may also notify you by other means, such as, but not limited to an email or a notification on our websiteThis policy is governed by Singapore law.