Hayden Reed PTE LTD and KML Associates PTE LTD (“we”, “our” or “us”) believe that protecting the security and privacy of your personal data is important. This Privacy Notice explains how we, as the Data Controller, collect, store, use, disclose and transfer (hereinafter “process”) your personal data. The personal data that we collect about you depends on the context of your interactions with us (e.g. if you are a candidate or a client).
1. Processing of personal data related to your use of our website and job applications.
Categories of personal data processed, and purpose of the processing
When visiting our website or using our services to apply for a job or find a suitable candidate for a permanent vacancy, (each a “Service Offering”), we may process the following categories of personal data:
Your contact information, such as full name, address, telephone number, mobile phone number and email address;
Organizational information, including job position and company name;
Information submitted as part of a support request, survey or comment or forum post;
Further personal data that you provide by filling in forms in our Service Offerings; and
Information on your online interaction with us, including your device and user identifier, in-formation on your operating system, sites and services accessed during your visit, the date and time of each visitor request.
Work history, employment preferences, references and the information contained in the CV(s) you provide us.
Where appropriate, proof of your eligibility to work in a relevant jurisdiction.
Where we are legally required to do so, details of any criminal offences.
Details of roles that you obtain through us and copies of correspondence exchanged with you and relevant hirers in relation to your introductions.
We also obtain personal data about you from third parties including (but not limited to):
Clients to whom we provide your CV and who provided feedback to us.
Former employers and referees who provide references.
Publicly available sources such as social media sites and LinkedIn, to enhance the information we hold in order to assist you better with finding suitable roles.
We process your personal data for the following purposes:
To provide you with our recruitment services.
To send you information about job opportunities, industry reports and insights, events, pro-motions and competitions.
To enable you to apply for jobs.
To provide you information with the aim of helping you find suitable employment opportunities.
To provide the Service Offering and functions which includes creating and administering your account, updating, securing, and troubleshooting, providing support, as well as improving and developing our Service Offerings;
To verify your identity where required;
To answer and fulfil your requests or instructions;
To provide you with access to specific information or offers;
As reasonably necessary to enforce the Service Offering’s terms, to establish or preserve a le-gal claim or defense, to prevent fraud or other illegal activities, including attacks on our information technology systems.
2. Processing of personal data related to your business relationship with us
Categories of personal data processed, and purpose of the processing
In the context of the business relationship with us, we may process the following categories of per-sonal data of consumers and contact persons at (prospective) customers, suppliers, vendors and partners(each a “Business Partner”):
Contact information, such as full name, work address, work telephone number, work mobile phone number and work email address;
Organizational information, including job position and company name;
Payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
Further information necessarily processed in a project or contractual relationship with us or voluntarily provided by the Business Partner, such as personal data relating to orders placed, payments made, requests, and project milestones;
Personal data collected from publicly available sources (including business and employment oriented social networks and websites), integrity data bases and credit agencies.
We may process the personal data for the following purposes:
Communicating with Business Partners about our services and projects, e.g. by responding to inquiries or requests or providing information about our services and candidates we introduce as part of our recruitment services;
Planning, performing and managing the (contractual) relationship with Business Partners;
Administrating and performing market analysis, sweepstakes, contests, or other customer activities or events;
Contacting Business Partners with information and offers concerning our services;
Ensuring compliance with legal obligations (such as record keeping obligations), export control and customs, Business Partner compliance screening obligations (to prevent white-collar or money laundering crimes), and our policies or industry standards; and
Solving disputes, enforce our contractual agreements and to establish, exercise or defend le-gal claims.
3. Processing of personal data for customer satisfaction surveys and for direct marketing
Where and as permitted under applicable law, we may process your contact information for direct marketing purposes (e.g. trade show invitations, newsletters with further information and offers concerning our services) and to carry out customer satisfactions surveys, in each case also by e-mail. You may object to the processing of your contact data for these purposes at any time by writing to info.singapore@reed.com or by using the opt-out mechanism provided in the respective communication you received.
4. Transfer and disclosure of personal data
We only transfer your personal data as described below:
We do not share your personal data with third parties, except where it is necessary to do so to provide the Service Offering (e.g. sharing it with prospective employers) and as set out in this Privacy Notice.
Affiliated Companies, Clients and sales partners
For the purpose of and to the extent necessary to conduct our business relationship with you, we may share your personal data with affiliates, potential employers (our clients) and other third parties (e.g., sales partners and agents).
Service Providers
We may also share your personal data with third party service providers who assist us in carrying out our business activities. These third parties act as our data processors and are bound by strict contractual provisions to only process your personal data under our instructions and for the limited purposes we permit them. These third parties include (but are not limited to) our accountants; auditors; external legal advisors; external IT providers; support and hosting ser-vice providers; printing, advertising, marketing and market research and analysis service providers, technical engineers, data storage and cloud providers and all other outsourced service providers (such as communication providers) that assist us in the provision of our services.
Other third parties
We may transfer personal data to other third parties in connection with complying with legal obligations or establishing, exercising or defending rights or claims (e.g., for court and arbitration proceedings, to regulators, law enforcement and government authorities, to attorneys and consultants).
The recipients of your personal data may be located outside of the country in which you reside.
5. Retention periods
We will keep your personal data for as long as we need to in order to fulfil the purpose we collected it for. This may be for an ongoing purpose, e.g., we will retain your personal data for the duration of our business relationship with you and beyond, as we often support candidates with job placements over many years and potentially throughout their careers.
We keep some personal data for longer than others. To determine the appropriate retention period for personal data, we consider factors such as the purposes for which we process your personal data, including any legal, regulatory, accounting and reporting obligations, the nature and amount of per-sonal data that we hold about you, and the potential risk of harm to you from unauthorised use or disclosure of your personal data.
However, you retain control over your personal data and may instruct us to stop looking for work for you at any time. When instructed by you, we will remove your records from our database unless we are required to keep it for legal reasons.
6. Your rights
The data protection laws in the jurisdiction in which you reside may entitle you to specific rights in relation to your personal data.
In particular, and subject to the legal requirements, you may be entitled to
Obtain from us confirmation as to whether or not personal data concerning you are being pro-cessed, and where that is the case, access to the personal data;
Obtain from us the correction of inaccurate personal data concerning you;
Obtain from us the erasure of your personal data;
Obtain from us restriction of processing regarding your personal data;
Data portability concerning personal data, which you actively provided;
Object, on grounds relating to your particular situation, to further processing of personal data concerning you; and
Withdraw your consent to our processing of your personal data.
7. Use of cookies and local storage
We use cookies and your browser’s Local Storage to make your visit to our website more convenient. Cookies are small text files that are stored on your device and enable us to recognize your browser, among other things. Cookies enable us to improve the comfort and quality of the services provided on the website. Cookies are also used to analyze the use of the website. Some of the cookies we use are deleted when your browser session ends, i.e. after you close your browser (so-called “session cookies”). Other cookies remain on your device during their respective validity period and enable us to recognize your browser on your next visit.
We store only necessary information in your browser’s Local Storage like language settings. The legal basis for the processing of personal data using technically necessary cookies and Local Storage entries is legitimate interests.
The legal basis for the processing of personal data using cookies for analysis or marketing purposes is your consent granted via the cookie banner.
The purpose of using technically necessary cookies is to enable you to use our website. Some functions on our website cannot be provided without using cookies or the Local Storage. For these it is necessary for the browser to be recognized even after a page change. The user data collected by technically necessary cookies is not used to create user profiles.
The use of the statistics and personalization cookies is for the purpose of improving the quality of our website and its content based on the consent you have granted. Using cookies enables us to learn how our website is used so that we can continue to optimize our services.
Cookies are stored on the user’s device, which transmits them to our site. Therefore, you as a user also have full control over the use of cookies. By changing the settings in your Internet browser, you can disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are disabled for the website, it may no longer be possible to fully use all functions of the website.
8. Automated decision-making and profiling
As a responsible company, we do not use your data for profiling or automated decision-making.
9. Security
To protect your personal data against accidental or unlawful destruction, loss, use, or alteration and against unauthorized disclosure or access, we use adequate physical, technical and organizational security measures.
10. Data privacy contact
We will support you with any data privacy related questions, comments, concerns or complaints or in case you wish to exercise any of your data privacy related rights. Please contact info.singapore@reed.com
Besides contacting us, you always have the right to approach the competent data protection authority with your request or complaint.
11. Legal grounds for processing your personal data
11. Legal grounds for processing your personal data
The Personal Data Protection Act requires us to provide you with information on the legal basis of the processing of your personal data.
The legal basis for our processing data about you is that such processing is necessary for the purposes of
exercising our rights and performing our obligations under any contract we make with you;
Compliance with our legal obligations; and/or
Legitimate interests pursued by. Generally, the legitimate interest pursued by us in relation to our use of your personal data is: (a) the efficient performance or management of (i) your use of the Service Offerings, and/or (ii) our business relationship with you; (b) the provision of recruitment services to you, (c) optimizing the performance of our website and user experience; (c) the provision of information about our services to you; and (d) responding to requests and enquiries.
In some cases, we may ask if you consent to the relevant use of your personal data. In such cases, the legal basis for us processing that data about you may (in addition or instead) be that you have consented.
International data transfers
In the event that we transfer your personal data outside of Singapore, we ensure that your data is protected in a manner which is consistent with the PDPA. Therefore, and if required by applicable law, we take the following measures:
We only transfer your personal data to affiliated companies outside of Singapore if adequate guarantees have been agreed with them to ensure the level of data protection.
We transfer personal data to external recipients outside Singapore only if the recipient has entered into EU Standard Contractual Clauses with us, or Adequacy decision.
Your competent data protection authority
In case of data privacy related concerns and requests, we encourage you to contact us atinfo.singapore@reed.com. Besides contacting us, you always have the right to approach the competent data protection authority with your request or complaint.
This data protection declaration is currently valid and has the status as of May 2024.
Due to the further development of our website or due to changed legal or official requirements, it may be necessary to change this data protection declaration. The current data protection declaration can be called up and printed out by you at any time on the website at https://www.reedglobal.sg