Data Protection Policy

For Clients & Pass Applicants

This Data Protection Policy is for Clients and Pass Applicants for Work Pass and/or related Passes Applications. 

For our General Data Protection Policy, please click here

1. Introduction

1.1 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 our Clients and their authorized representatives (“Clients”) and individuals employed by or applying for employment with our Clients (“Pass Applicants”) in accordance with the Personal Data Protection Act 2012 (“PDPA”) of Singapore.

1.2 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 Clients and Pass Applicants 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. Clients – include all individuals/companies whom we deal with for the purpose of providing work pass and related passes application services for their business; and
3.2.2. Pass Applicants – which includes individuals and their dependants whose personal data FCS Careers collects, uses and discloses to the authorities for the purpose of obtaining a work pass with our Client, their employer, in Singapore.

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 Client, personal data which we may collect includes, without limitation, the following:

3.4.1. Name;
3.4.2. Address, telephone numbers and other contact details;
3.4.3. Details of your job title/description and organisational needs;
3.4.4. Information contained in the Business Profile, including personal identification number;
3.4.5. Information required on Authorisation Forms, including personal identification number;
3.4.6. Records of our interaction and any confidential feedback they may give FCS Careers regarding our candidates

3.5 If you are a Pass Applicant, personal data which we may collect includes, without limitation, the following:

3.5.1. Name or alias;
3.5.2. Gender;
3.5.3. NRIC/FIN or passport number;
3.5.4.
Birth certificates, marriage certificates;
3.5.5. Travel document page, including personal particulars and photograph;
3.5.6. Date of birth;
3.5.7. Nationality, and country and city of birth;
3.5.8. Residential & mailing address, telephone numbers, email address and other contact details;
3.5.9. Employment and training history;
3.5.10. Salary information and bank account details, including income information;
3.5.11. Educational certificates and transcripts;
3.5.12. Details of next-of-kin, spouse and other family members;
3.5.13. Work-related health issues and disabilities;
3.5.14.
Spouse’s travel document page including personal particulars and photograph, marriage certificate;
3.5.15. Child’s travel document page including personal particulars and photograph, birth certificate and/or official adoption papers;
3.5.16. Photographs and other audio-visual information;
3.5.17. Any additional information provided to us by the Pass Applicant or by the Client on behalf of the Pass Applicant.

3.6 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.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).

3.7 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 your business relationship 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 employer, employment intermediaries or job agents), 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. 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).

4.2 If you are a Client, your business contact information and 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. Maintaining a client and business relationship;
4.2.2. Providing work pass application services to you and your company;
4.2.3. Representing you and your company when communicating with relevant authorities or related third parties in order to fulfil our contract of service to you;
4.2.4. Submitting applications to the authorities on behalf of you or your company, as authorised by you;
4.2.5. Complying with our internal policies and procedures; and
4.2.6. 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.

4.3 If you are a Pass Applicant, your personal data and the personal data of your dependants will be collected and used by us and we may disclose such 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. Submitting applications to the authorities, as authorised by your potential employer, our Client;;
4.3.2. Representing you or our Client when communicating with relevant authorities or related third parties in order to fulfill our contract of service with our Client;
4.3.3. Complying with our internal policies and procedures;
4.3.4. Meeting any legal or regulatory obligations or requests issued by any court, legal or any regulatory bodies to conduct audit checks, surveillance and investigation.

4.4 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.

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. 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 withdrawal 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. Data Protection Officer

13.1 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

14. Effect of Policy & Changes to Policy

14.1 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.

14.2 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.

Effective date: 4 September 2023
Last updated: 21 November 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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Call us at +65 6737 3638.