Your Personal Data is Important To Us
1. Preamble
This Personal Data Protection Policy (“Policy”) of Soon Hock Group of companies (“Company”) sets out the controls and procedures to ensure we comply with the provisions of the Personal Data Protection Act 2012 of Singapore (‘PDPA’) namely;
This Policy applies to visitors, customers and consultants engaging with the Company and it shall be read in conjunction with the Personal Data Protection Act 2012 (“PDPA”) and all PDPA Advisory guidelines issued by the Personal Data Protection Commission (“PDPC”).
The scope of the Personal Data Protection Management Policy shall include all entities under the Soon Hock Group of companies listed below:
2. Definitions
Customer: any individual or legal entity that uses services or buys products of the Company.
Individual: any natural person, whether living or deceased, whom the Company collects, uses, and discloses their personal data, including personal data collected in the past.
Personal Data: means data, whether true or not, about an individual who can be identified (1) from the data or (2) from that data and other information to which the Company has or, is likely to have access.
Personal Data Collected From Overseas (“PDCFO”): All data protection obligations under the PDPA would apply to Personal Data collected from overseas but stored, used and disclosed by the Company. Only the Protection and Retention obligations of the PDPA shall apply if the Personal Data is received from overseas for processing by the Company as a data intermediary.
The PDPA does not apply to the following categories of Personal Data:
However, please note that we may not be able to continue with our services to you or to allow you to our office premises, or attend our events, where you have withdrawn your consent for our collection, use or disclosure of your personal data.
We may collect, disclose, or use your personal data pursuant to an exception under the Personal Data Protection Act or other written law such as during the following situations:
3. Information Collection
We generally do not collect your personal data unless (a) 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, 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).
We may collect and use your personal data for any or all of the following purposes:
4. Non-Disclosure
We do not sell, release, distribute or lease your Personal data to third parties. We may share data with trusted partners to help us perform analysis, send you email or provide customer support. All such third parties are prohibited from using your personal information except to provide these services to us, and they are required to maintain the confidentiality of your Personal data.
5. Disclosure of Personal Data
We may also disclose your personal data:
6. Reliance on the Legitimate Interests Exception
In compliance with the PDPA, we may collect, use, or disclose your personal data without your consent for the legitimate interests of the Company. In relying on the legitimate interests’ exception of the PDPA, the Company will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
In line with the legitimate interests’ exception, we will collect, use, or disclose your personal data for the following purposes:
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.
7. Security of Personal Data
We strive to maintain the safety of your Personal Information. We use a reasonable physical and digital security system to store your personal information.
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 minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, 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, usage of one-time password /multi-factor authentication (mfa) to secure access, and security review and testing performed regularly.
The implementation of this system is to protect your information from unauthorized access, use, disclosure, or destruction. The information you provide to us may be stored on the secure servers of our trusted service providers, which are located in Singapore and elsewhere.
However, no internet-based service is completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Therefore, by visiting our website, you acknowledge the potential for unauthorized access and agrees to assume the risk.
In the event of a breach that affects your personal information, you will be notified within a reasonable timeframe of such breach and measures we took to rectify the breach. Note that, you may request at any time to access and delete your information with us.
8. 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 fourteen (14) 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 goods or 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 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.
9. 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 thirty (30) 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).
10. Retention time
The Company retains your personal information for as long as is necessary to fulfil the purpose for which it was collected and whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Company may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, 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.
11. 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.
12. Transfers of Personal Data Outside of Singapore
We generally do not transfer your personal data to countries outside of Singapore, except where the transfer is necessary to fulfil our performance of a contract or where the transfer is necessary for the use or disclosure where exceptions to consent for use or disclosure applies under the PDPA. Where such transfers are made, 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.
13. Links to Other Websites
Our website may contain links to other websites. This Privacy Policy only applies to this website so when you link to other websites you should read their own privacy policies.
14. Changes to This Privacy Policy
The Company reserves the right to make changes to this privacy policy at any time. The Company encourages you to periodically review this Privacy Policy to be informed of how the Company is protecting your information.
15. Contact Us
The Company welcomes your comments regarding this Privacy Policy. If you believe that the Company has not adhered to this Privacy Policy, please contact us at +65 6661 6800 or email: dpo@soonhock.com.sg.
This Data Protection Notice (“Notice”) sets out the basis upon which Soon Hock Group of companies (“Company”) may collect, use, disclose or otherwise process personal data of job applicants in accordance with 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 organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
Application of this notice
This Notice applies to all persons who have applied for any such position with us (“job applicants”).
The scope of the Data Protection Notice for Job Applicant shall be applicable to job applicants applying to the Company, which includes the entities as listed below:
Personal Data
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.
Personal data which we may collect are your:
Note that at recruitment stage, we will dispose of any unsolicited personal data (like, NRIC/ Passport number) that has been transmitted to us. Therefore, do not send us personal data that has not been requested in the list above.
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 generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your employment or job application 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).
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:
We also assume that you have obtained necessary consent from the Referees (if any) before providing referee details for the purpose of this job application.
The purposes listed in the above clauses 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).
After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes.
We may collect, disclose, or use your personal data pursuant to an exception under the Personal Data Protection Act or other written law such as during the following situations:
You have choices regarding our collection, use or disclosure of your personal data. You have the right to object to the processing of your personal data and withdraw your consent in a manner described in withdrawing clause below. However, please note that we shall not be able to continue with your job application in the absence of required information.
Reliance on the Legitimate Interests Exception
In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of the Company or another person. In relying on the legitimate interests’ exception of the PDPA, the Company will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
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.
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. As a job applicant, 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 and effect your request within ten (10) days of receiving it.
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). 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, 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 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).
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.
Protection of Personal Data
We strive to maintain the safety of your Personal Information. We use a reasonable physical and digital security system to store your personal information.
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 minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, 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, usage of one-time password /multi-factor authentication (mfa) to secure access, and security review and testing performed regularly.
The implementation of this system is to protect your information from unauthorized access, use, disclosure, or destruction. The information you provide to us may be stored on the secure servers of our trusted service providers, which is located in Singapore and elsewhere.
However, no internet-based service is completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Therefore, by visiting our website, you acknowledge the potential for unauthorized access and agrees to assume the risk.
In the event of a breach that affects your personal information, you will be notified within a reasonable timeframe of such breach and measures we took to rectify the breach. Note that, you may request at any time to access and delete your information with us.
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.
We may further verify your identity when you attend job interviews with us by sighting your national identification document (i.e. NRIC for Singapore citizens or Passport for foreigners).
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:
Contact No. : +65 6661 6800
Email Address : dpo@soonhock.com.sg