Published: November 2017
Last Amended: August 2019
This Data Protection Policy (“Policy”) sets
out the basis upon which Jigyasa (“we”,
“us” or “our”) may collect, use, disclose or otherwise process personal data of
employees and job applicants in accordance with the Personal Data Protection
Act (“PDPA”). 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
APPLICATION OF THIS POLICY
- The policy
applies to all data that Jigyasa collects on behalf of clients, or on its own
towards delivering its service. It is
aimed at understanding how Jigyasa collects, uses, discloses, stores and
manages the data it collects.
- As used in this Policy, “personal data” means 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.
- Personal data which we may collect includes, without limitation, your:
- name or alias, gender, date of birth, nationality, and country and city of birth;
- mailing address, telephone numbers, email address and other contact details;
- resume, educational qualifications, professional qualifications and certifications and employment references;
- employment and training history;
- work-related health issues and disabilities; and
- Appraisal data
- Assessment Data
- Bank account details
COLLECTION, USE, PROCESSING AND DISCLOSURE
OF PERSONAL DATA
- We generally collect personal data that that is knowingly and voluntarily provided in the course of or in connection with the service we are required to provide in the course of doing business 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 employer).
- We respect the confidentiality of the personal data you have provided to us. Jigyasa does not share, sell, rent or release any personal data collected to any individuals, companies or groups. Any information we collect is used for Jigyasa’s own purposes as described in this PDPA policy.
- Jigyasa uses third party service providers such as Professional advisors, consultants, technical specialists to ensure that we are able to deliver our services to our clients.
- In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above- stated Purposes.
- The third parties whom we conduct business are only authorized to use your information to perform the service for which they were hired. As part of our agreement with them, they are required to follow the PDPA laws and policies that we provide, and to take reasonable measures to ensure your personal data is secure.
- 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 or your representative or your employer in writing.
- Upon receipt of your or your employer or representative’s 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 30 days of receiving it.
ACCESS TO AND CORRECTION OF PERSONAL DATA
- 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 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 using the contact us page on our website with the subject header “Correction to Personal Data”
- 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 the PDPA).
- 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.2 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
- 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.
- 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.
RETENTION OF PERSONAL DATA
- 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.
- 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 OUTSIDE OF
- Our servers are hosted in the US and 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.
- 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, please use the contact us page of our website.
EFFECT OF POLICY AND CHANGES TO POLICY
- 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.
- As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
- We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion.