Data Protection Notice for Employees, Freelancers, Contractors and Candidates

This Data Protection Notice (“Notice”) sets out the basis upon which Sleek (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of employees, freelancers, contractors, and candidates. This Notice 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

1. This Notice applies to: 
   1. persons engaged in a contract for service with us (such persons being ‘freelancers’ or ‘contractors’); 
   2. persons engaged in a contract of service with us; 
   3. interns working at or attached to us; 
   4. persons who have (directly or indirectly through an agent) applied for a position with Sleek or have otherwise indicated an interest in working for Sleek in the future and have provided Personal Data during this process of engagement (“Candidate”),

(the persons in (a), (b) and (c) above, whether on a part-time or full-time basis, and all such persons hereinafter collectively referred to as “Employee”).

2. In this notice, references to the term “employment” shall be construed to include employment, freelance and contract service arrangements, and internships (as may be applicable) with us. 

PERSONAL DATA 

3. As used in this Notice, “personal data” means data, whether true or not, but as provided to us, about an Employee or a Candidate 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. 

4. If you are a candidate, personal data which we may collect includes, without limitation, your: 
   1. name or alias; 
   2. mailing address, telephone numbers, email address and other contact details; 
   3. resume, educational qualifications, professional qualifications and certifications and employment references; 
   4. employment and training history; 
   5. salary information; and
   6. work authorization.

5. If you are an Employee, personal data which we may collect in the context of your employment with us includes, without limitation, your: 
   1. name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country of birth;
   2. mailing address, telephone numbers, email address and other contact details; 
   3. employment and training history; 
   4. salary information and bank account details; 
   5. details of your next-of-kin; 
   6. records on leave of absence from work; 
   7. Photographs, and biometric information; 
   8. performance assessments and disciplinary records; 
   9. any additional information provided to us by you as a job applicant (that is, prior to being engaged by us); and 
   10. information technology related data such as logs, emails, system data and any other communication with Sleek systems.

6. Other terms used in this Notice shall have the meanings given to them in the Personal Data Protection Act (“PDPA”) (where the context so permits). 

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA 

7. 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 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. In addition, we may collect and use any communications that originate from the connection or use of Sleek’s related services or infrastructure, which may include personal data such as device settings, emails, device logs, device information,phone number, used applications, internet use and network traffic. 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).

8. As a Candidate, 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:
   1. assessing and evaluating your suitability for employment in any current or prospective position within the organisation; 
   2. conducting background, or reference checks; 
   3. facilitating our compliance with any laws, customs and regulations which may be applicable to us; and 
   4. verifying your identity and the accuracy of your personal details and other information provided.

9. As an Employee, 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: 
   
   1. performing obligations under or in connection with your contract of employment with us, including payment of remuneration and tax; 
   2. all administrative and human resources related matters within our organisation, including administering payroll, granting access to our premises and computer systems, processing leave applications, administering benefits, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource policies; 
   3. managing and terminating our employment relationship with you, including monitoring your internet access and your use of our intranet email to investigate potential contraventions of our internal or external compliance regulations, and resolving any employment related grievances; 
   4. determining proper use of our networks and systems, ensuring the security of our networks and systems, and investigating and preventing security incidents; 
   5. assessing and evaluating your suitability for employment/appointment or continued employment/appointment in any position within our organisation; 
   6. ensuring business continuity for our organisation in the event that your employment with us is or will be terminated; 
   7. performing obligations under or in connection with the provision of our goods or services to our clients;
   8. facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organisation, or corporate restructuring process; and 
   9. facilitating our compliance with any laws, customs and regulations which may be applicable to us. 

10. 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 or an unsuccessful or deferred job application) 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). 
11. Please note that if you choose not to provide us with your Personal Data or choose not to consent to our processing of your Personal Data, we may not be able to provide some or all the services necessary to administer and manage your employment or application (as the case may be) or respond to your other requests; for Candidates, we would not be able to evaluate your suitability against our employment opportunities.

WITHDRAWING CONSENT BY CANDIDATES

12. The consent that Candidates 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.
13.  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 thirty (30) days of receiving it. 
14. 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 11 above. 
15. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA 

16. If you wish to make (a) a 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 (directly, or indirectly via your HR contact) at the contact details provided below. 
17. 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. 
18. We will respond to your access request as soon as reasonably possible. 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 applicable law). 
19. 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 

20. 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, 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. 
21. 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. 
22. In the event of a notifiable data breach, which concerns your personal data you will be informed without undue delay.

ACCURACY OF PERSONAL DATA 

23. 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 (directly, or indirectly via your HR contact) in writing or via email at the contact details provided below. 

RETENTION OF PERSONAL DATA 

24.  We may retain your personal data for as long as it is necessary to fulfill the purposes for which they were collected, or as required or permitted by applicable laws. 
25. 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 OVERSEAS 

26. In the course of your employment, some personal data may be disclosed and transferred by us, including to other members of the Sleek group of companies, a third party vendor or service provider, some of whom are located in countries outside Singapore. We will make sure that the standard of protection afforded to personal data so transferred is comparable to the protection afforded under the applicable laws and regulations in Singapore.

DATA PROTECTION OFFICER 

27. 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 by email or post to: 

160 Robinson Road, #14-04 SBFCenter

Singapore 068914

Email: [email protected] 

EFFECT OF NOTICE AND CHANGES TO NOTICE

28. This Notice applies in conjunction with any other policies, notices, contractual clauses, code of conduct, and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us. 
29. We may revise this Notice from time to time by giving notice. If you are a Candidate, your continued participation in our recruitment process constitutes your acknowledgement and acceptance of such changes. As an Employee, your continued employment constitutes your acknowledgement and acceptance of such changes.