1. INTRODUCTION
Sleek Tech Pte Ltd and its group companies (“we”, “our” or “us”) is providing this Data Protection Statement to you because you are applying to work with us as an employee, worker or contractor.
This statement sets out the basis on which we will process your personal information (“Information”). Please read it carefully to understand our practices regarding your personal information and how we will use it.
2. ABOUT US
We are the data controller of the personal data of prospective employees, workers and contractors, and is subject to applicable data protection laws.
Contacting us:
If you have any questions about this Data Protection Statement or your Information, or wish to exercise any of your rights as described in this statement or under applicable data protection laws, you can contact our designated Data Protection Officer by email at [email protected].
3. WHAT TYPES OF DATA ARE PROTECTED?
Personal Data
This Data Protection Statement applies to your “personal data”, which is any information relating to you as an identified or identifiable person. This data is referred to in this Data Protection Statement as “Information”.
Special categories of personal data
Within the broad range of personal data, the following are “special categories of personal data” which are subject to a greater degree of protection:
- physical or mental health;
- racial or ethnic origin;
- political opinions;
- trade union membership;
- religious beliefs;
- sexual life; and
- genetic and biometric data.
4. WHAT INFORMATION WE COLLECT
Information you give us
You may give us Information by filling in forms online, by corresponding with us by phone, email, in person, or otherwise, or via a recruitment agency or other third party.
Information we collect about you
The Information that we may collect about you includes, but is not limited to, the following:
- name;
- home address;
- contact details (such as phone numbers and email addresses);
- date of birth;
- gender;
- marital status;
- copies of your passport, driving licence and similar documents;
- education history, training and professional experience;
- current and past employment details;
- immigration status and work permits;
- languages spoken and level of proficiency; and/or
- other information given in your CV.
Special categories of personal data
Information includes such “special categories of personal data” (see the description provided above) as you and any medical professionals provide to us.
Information provided by third parties
5. INFORMATION PROVIDED BY THIRD PARTIES
We may also collect Information from external sources, such as those that are commercially available to us.
Some of the Information we collect (as described in section 4), and additional Information, may be provided to us by other platforms which we use as part of our recruitment process.
During the recruitment process, we may also research Information regarding your skills, experience or qualifications and comments and opinions made public on social networking sites such as LinkedIn and other social media networks.
We may also receive Information from organisations such as credit reference agencies, fraud prevention agencies and referees.
6. DATA RELATING TO CRIMINAL CONVICTIONS & OFFENCES
We may also collect and store personal data relating to criminal convictions and offences. This data is only processed:
- if you have given your consent to the processing; or
- if it is necessary for the purposes of performing or exercising our or your obligations or rights under law; or
- if it is necessary for the prevention or detection of an unlawful act and it is necessary for reasons of substantial public interest; or
- in connection with any legal proceedings (including prospective legal proceedings) and/or the obtaining of legal advice.
7. WHAT WE DO WITH YOUR INFORMATION AND ON WHAT BASIS
We process Information (other than special categories of personal data) for the reasons listed below. The legal justification for the processing of the Information is, in each case, one or more of these reasons. Specific examples are given – some of which may overlap, as there may be more than one reason for processing Information.
Where we have a legitimate interest
Data protection law allows us to process Information where it is necessary for the purposes of our legitimate interests. We consider it to be in our legitimate interests to process Information for the following purposes:
- recruitment processes (including negotiation and communicating with you in relation to your application);
- considering your suitability for employment/work, taking up references, and conducting appropriate checks;
- dealing with any legal disputes involving you or other prospective, current or former employees, workers or contractors;
- reporting to government entities.
If you do not agree with the processing of Information on the basis that it is in our legitimate interests to do so, please inform us using the contact details at the beginning of this Data Protection Statement, following which we shall cease to process Information for that purpose, unless certain exceptions apply.
Special categories of personal data
- We may process “special categories of personal data” for the purposes of:
- performing or exercising our or your obligations or rights under employment law or other laws, including for assessing suitability for particular jobs and considering whether adjustments may need to be made to accommodate an individual with a disability;
- where it is in the public interest, such as for equal opportunities monitoring;
- establishing, bringing or defending legal claims; and
- in the case of information about your physical or mental health, to enable us to assess your working capacity and for occupational health purposes.
We may also process “special categories of personal data” in other limited circumstances, with your explicit written consent. We do not need your consent to process “special categories of personal data” in circumstances where we already have a legal right to do so and we carry out such processing in accordance with this statement. If we do ask you for your written consent, we will provide you with full details of the information we are seeking from you and the reason why, in order for you to make an informed decision.
8. DISCLOSURE OF INFORMATION TO THIRD PARTIES
Disclosure of your information to third parties
For the purposes set out in section 7 above, we may share Information with:
- our group companies;
- professional advisors (including lawyers, accountants and auditors);
- legal and regulatory authorities such as the IRAS and MOM; and
- Other government/state related entities for law enforcement purposes.
We may also disclose Information to third parties where it is in our legitimate interest to do so, including for the following reasons:
- in the event that we sell or buy any business or assets, in which case we may disclose Information to the prospective seller or buyer of such business or assets; or
- if we are under a duty to disclose or share Information in order to comply with any legal obligation.
Save as set out in this Data Protection Statement, or as required by law, we do not sell Information or disclose it to any third parties without your consent.
9. HOW LONG WE KEEP YOUR INFORMATION
We will keep your Information for as long as necessary to fulfil the purposes described in our global privacy policy or in the terms of any contract that we enter into or for as long as we are required to do so by law or in order to comply with a regulatory obligation.
10. YOUR RIGHTS
Access to your Information and updating your Information
- You have the right to access Information that we hold about you, subject to certain limited exceptions provided by law. If you so request, we shall provide you with a copy of Information which we are processing and hold about you (“data subject access request”). For any further copies which you request, we may charge a reasonable fee based on administrative costs.
- You also have the right to receive such Information in a structured and commonly used format so that it can be transferred to another data controller (“data portability”).
- We want to make sure that your Information is accurate and up to date. You may ask us to correct or remove information which you think is inaccurate.
Right to object to processing in certain circumstances You also have the right to object, on grounds relating to your particular situation, at any time to the processing of your Information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your Information unless:
- the processing is nevertheless necessary for the performance of a contract that you enter into with us;
- the processing is necessary for the establishment, exercise or defence of legal claims;
- we have a legal or regulatory obligation for which the processing of the Information is necessary; or
- we can demonstrate that our legitimate interest is sufficiently compelling to override your fundamental rights and freedoms.
Your other rights
You also have the right to request that we rectify your Information if it is inaccurate or incomplete. In certain limited circumstances, you have the right to request the erasure of your Information (‘right to be forgotten’).
11. INTERNATIONAL TRANSFERS
As an international organisation, authorised personnel may access your Information in any country in which we operate. Therefore, it may be necessary to transfer your details to members of our group located outside of Singapore. We will make sure that your data is protected in the same way as it is protected in Singapore
Regardless of where your Information is transferred, we shall ensure that your Information is safe and shall take all steps reasonably necessary to put in place appropriate safeguards to ensure that your Information is treated securely and in accordance with this statement and applicable law.
12. COMPLAINTS
You also have the right to complain to the Personal Data Protection Commission in Singapore about our data processing activities here.
