General Data Protection Policy
For Candidates and Job Applicants, Clients and Business Relations, and Referees
This Data Protection Policy explains how we collect, use and disclose personal data, as well as your access and rights to your personal data.
1. Introduction
1.1 At FCS Careers, the protection of personal data is our priority. We value your privacy and are committed to ensuring your personal data is secure and treated with care at all times.
1.2 This Data Protection Policy (“Policy”) sets out the basis upon which FCS Careers Pte Ltd (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of candidates and job applicants, clients and business relations including office visitors, and referees, in accordance with the Personal Data Protection Act 2012 (“PDPA”) of Singapore.
1.3 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.
2. Application of this Policy
2.1 This Policy applies to candidates and job applicants, clients and business relations, including partners, contractors and office visitors, as well as referees, whose personal data we collect to serve the purposes for which the persons have submitted the information.
3. Personal Data
3.1 As used in this Policy, “personal data” refers to data, whether true or not, about an individual 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.
3.2 The types of information that we typically collect and hold will vary depending on our relationship with you. These relationships are generally categorised as:
3.2.1. Candidates and Job Applicants – include individuals who approach us, or who are engaged by us, in the process of seeking employment with us or with our clients;
3.2.2. Clients and Business Relations – include individuals and company representatives with whom we deal for the purpose or intention of providing recruitment solutions or other business services, as well as visitors to our office premises;
3.2.3. Referees – include individuals who have provided their contact details to a candidate or job applicant, thereby consenting to be being contacted by us in order to evaluate the candidate’s or job applicant’s capabilities and suitability for employment
3.3 We may also collect personal data from you if you contact us, for example by phone or by email, and do not fall into one of the above categories.
3.4 If you are a Candidate or Job Applicant, personal data which we may collect includes, without limitation, the following:
3.4.1. Name and/or alias(es)
3.4.2. Gender
3.4.3. NRIC/FIN or passport number
3.4.4. Date of birth
3.4.5. Nationality, country and city of birth
3.4.6. Contact details, including residential and mailing addresses, telephone numbers, and email address
3.4.7. Educational qualifications, professional qualifications and certifications
3.4.8. Employment references
3.4.9. Employment and training history
3.4.10. Salary information, including previous salary and job offer salary information
3.4.11. Disability and Health-related information, including medical examination results
3.4.12. Photographs
3.4.13. Interests
3.4.15. Results of background checks, aptitude or psychological assessment results
3.4.16. Information regarding your COVID-19 vaccination or other inoculation status and/or ability to enter the workplace in accordance with prevailing government advisories or regulations
3.4.17. Video footage if you enter our office premises
3.4.18. Any other information contained on your resume and/or curriculum vitae
3.4.19. Any other information that you, your referees or our clients provide to us, including personal feedback and notes of our interactions with you and/or others in relation to your suitability for work with us or through us
3.5 If you are a Client or Business Relation, personal data which we may collect include business contact information such as, without limitation, the following:
3.5.1. Name
3.5.2. Address, telephone numbers and other contact details
3.5.3. Details of your job title/description and organisational needs
3.5.4. Records of our interaction and any confidential feedback you may give us regarding our candidates
3.5.5. Video footage if you enter our office premises
3.6 If you are a Referee, personal data which we may collect includes, without limitation, the following:
3.6.1. Name
3.6.2. Contact details, including your address, telephone numbers and email address
3.6.3. Employment information, including name of employer and job title
3.6.4. Relationship with candidate
3.6.5. Confidential opinions about a candidate and their suitability for work with or through us
3.7 We only collect, use and disclose personal data with your consent or deemed consent or as otherwise permitted under the PDPA or other applicable laws and regulations.
3.8 Other terms used in this Policy shall have the meaning given to them in the PDPA (where the context so permits).
4. Collection, Use and Disclosure of Personal Data
4.1 We generally collect personal data that
4.1.1. you knowingly and voluntarily provide in the course of or in connect with us providing our services to you, or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”), after
4.1.1.1. you (or your authorized representative) have been notified of the purposes for which the data is collected, and
4.1.1.2. you (or your authorized representative) have provided written consent to the collection and usage of your personal data for the purposes, or
4.1.2. 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).
4.2 If you are a Candidate or Job Applicant, your personal data will be collected and used by us and we may be disclose your personal data to third parties where necessary. We will use the collected Personal Data in accordance with the purpose, which you have consented to. To the extent applicable, it includes the following (“Purpose”):
4.2.1. Assessing and evaluating your suitability for employment in any current or prospective position in our organisation or with our clients;
4.2.2. Introducing and recommending you (including sending your resume and Personal Data) to our clients, our affiliated companies, agents or sub-contractors that are engaged in the same or similar recruitment business as us, for recruitment purposes or recruitment collaborative purposes;
4.2.3. Verifying your identity and the accuracy of your personal details and other information provided;
4.2.4. Conducting pre-employment and related background checks (whether internally by us or through our vendors);
4.2.5. Sending you directly or via our clients, our affiliated companies, agents or sub-contractors for reasoning test, psychometric test, personality test, career aptitude test or any tests to determine your skills and suitability for the job(s);
4.2.6. Discussing with your past employer(s), educational institution(s) to establish your employment history and educational history, or for reference checks;
4.2.7. Contacting you to make arrangements for interviews;
4.2.8. Calling you (including leaving voice messages and/or short message services (SMS), WhatsApp or sending you text or other communication (text or image) applications for mobile device or via any electronic means (including electronic mailing) or send invitations to you on job alerts;
4.2.9. Sending you market research surveys and/or satisfaction surveys;
4.2.10. Meeting and complying with our internal policies and procedures;
4.2.11. Storage and processing of your Personal Data;
4.2.12. Meeting any legal or regulatory obligations or requests issued by any court, legal or any regulatory bodies (including the agents of the regulatory bodies) to conduct audit checks, surveillance and investigation; and
4.2.13. Any other purposes which are reasonably related to the aforesaid.
4.3 If you are a Client or Business Relation, your personal data will be collected and used by us and we may be disclose your personal data to third parties where necessary. We will use the collected Personal Data in accordance with the purpose, which you have consented to. To the extent applicable, it includes the following (“Purpose”):
4.3.1. Business development and maintaining a client or business relationship with you;
4.3.2. Administering and managing the contractual relationship between us and your company;
4.3.3. Representing you and your company when communicating with relevant authorities, prospective candidates or related third parties in order to fulfil our contract of service to you;
4.3.4. Complying with our internal policies and procedures;
4.3.5. Pursuing legitimate interests, which include the protection of company assets and ensuring the security of our information systems and people; and
4.3.6. Meeting any legal or regulatory obligations or requests issued by any court, legal or any regulatory bodies (including the agents of the regulatory bodies) to conduct audit checks, surveillance and investigation.
4.4 If you are a Referee, your personal data will your personal data will be collected and used by us and we may disclose your personal data to third parties where necessary. We will use the collected Personal Data in accordance with the purpose, which you have consented to. To the extent applicable, it includes the following (“Purpose”):
4.4.1. Confirming your identity and authority to provide references; and
4.4.2. Assessing the suitability of a candidate.
4.5 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).
5. Notification Obligation
5.1 We will inform you of the purposes for which your Personal Data will be collected, used and disclosed in order to ensure you are able to provide informed consent.
5.2 If you are a Candidate or Job Applicant, you may be required to provide the details of your Referees for us to perform our services. When submitting personal data of your Referees, you agree to notify each referee of the purpose of our use of their personal data and obtain their permission to disclose their data for the purposes.
6. Accuracy of Personal Data
6.1 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.
6.2 Please note that if the Personal Data provided by you or your authorized representative is inaccurate, incomplete or outdated, we may not be able to fulfil the purposes stated in this policy.
7. Deemed Consent
7.1 If you voluntarily provide your Personal Data to us and for a reasonable purpose, you will be deemed to have consented to our collection, use or disclosure of such data.
7.2 If you have provided your Personal Data to our client for a reasonable purpose, and it is reasonably necessary for our client to disclose the personal data to us to fulfill the contract or perform the transaction between you and our client, you are deemed to have consented to our collection, use or disclosure of such data.
8. Withdrawing Consent
8.1 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. If you are a candidate, you may withdraw consent and request us to stop 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.
8.2 Upon the 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.
8.3 We will respond to your withdrawal request as soon as reasonably possible. Should we not be able to respond to your withdrawal request within ten (10) 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.
8.4 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 in clause 8.1 above.
8.5 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 and Correction of Personal Data
9.1 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 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 updates 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.
9.2 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.
9.3 We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within ten (10) 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).
9.4 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.
10. Protection of Personal Data
10.1 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, 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.
10.2 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.
11. Retention of Personal Data
11.1 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.
11.2 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, and are no longer necessary for legal or business purposes.
12. Transfers of Personal Data outside of Singapore
12.1 We may also transfer your personal data, as applicable, to our employees, directors, clients (and its agents), suppliers (including but not limited to IT providers, financial and legal advisors), authorities (and its agents), and to our other affiliates, based locally or abroad, in order to reasonably achieve the Purpose.
12.2 Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing 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.
13. Collection and Disclosure of Personal Data as Regulatory Requirement
13.1 Under clause 5a and 5b(i) of the Ministry of Manpower (MOM)’s Employment Agencies Licence Conditions, we are required to collect the NRIC or FIN numbers of applicants referred to our clients for permanent or contract job positions of at least 6 months with a fixed monthly salary of $3,300 and above.
13.2 As this is a regulatory requirement, we are permitted to collect, use and disclose your NRIC or FIN number, and are unable to provide recruitment services to you if you do not disclose such information. In view of fair employment practices, your NRIC or FIN will only be collected upon job offer.
14. Data Protection Officer
14.1 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:
- Data Protection Officer: Cleon Tan
- Email Address: dpo@fcs-careers.com
- Contact Number: +65 6737 3638
- Address: FCS Careers Pte Ltd, 380 Jalan Besar, #09-04, Singapore 209000
15. Effect of Policy & Changes to Policy
15.1 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.
15.2 We may revise this Policy 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 use of our services and/or participation in our recruitment process constitutes your acknowledgement and acceptance of such changes.
Valid from 28 November 2018.
Last updated on 11 September 2023
Requests for Access, Correction or Withdrawal of Personal Data
If you would like to make a request for access, correction or withdrawal of personal data, you may do so by sending us a Request Form in person, by registered post or via email to dpo@fcs-careers.com.
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