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PERSONAL DATA PROTECTION POLICY

PERSONAL DATA PROTECTION POLICY FOR EMPLOYEES AND JOB APPLICANTS
 
This Personal Data Protection Policy (“Policy”) sets out the basis which Hanwell Group of Companies (“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 purposes.
 
APPLICATION OF THIS POLICY
1. This Policy applies to all persons engaged in a contract of service with us (whether on a part time,
temporary or full-time basis) and interns and trainees working at or attached to us (collectively referred to as
“employees”) as well as persons who have applied for any such position with us (“job applicants”), and all
references to “employment” shall apply equally to internships and traineeships (as may be applicable).
 
PERSONAL DATA
2. As used in this Policy, “personal data” means data, whether true or not, about an employee or a job
applicant 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. If you are a job applicant, personal data which we may collect includes, without limitation, your:
(a) name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country and city of
birth;
(b) mailing address, telephone numbers, email address and other contact details;
(c) resume, educational qualifications, professional qualifications and certifications and employment
references;
(d) employment and training history;
(e) work-related health issues and disabilities; and
(f) photographs.
4.If you are an employee, personal data which we may collect in the context of your employment with us
includes, without limitation, your:
(a) name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country and city of
birth;
(b) mailing address, telephone numbers, email address and other contact details;
(c) employment and training history;
(d) salary information and bank account details;
(e) details of your next-of-kin, spouse and other family members;
(f) work-related health issues and disabilities;
(g) records on leave of absence from work;
(h) photographs and other audio-visual information;
(i) Emergency contact;
(j) performance assessments and disciplinary records; and
(k) any additional information provided to us by you as a job applicant (that is, prior to being engaged as an
employee).
5. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so
permits).
 
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
6. 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 written 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.
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).
7. If you are a job applicant, 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:
(a) assessing and evaluating your suitability for employment in any current or prospective position within the
organisation; and
(b) verifying your identity and the accuracy of your personal details and other information provided.
8. If you are 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:
(a) performing obligations under or in connection with your contract of employment with us, including
payment of remuneration, Central Provident Fund contributions and Income Tax;
(b) 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
your insurance and other benefits, processing your claims and expenses, investigating any acts or defaults (or
suspected acts or defaults) and developing human resource policies;
(c) 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;
(d) assessing and evaluating your suitability for employment/appointment or continued
employment/appointment in any position within our organisation;
(e) ensuring business continuity for our organisation in the event that your employment with us is or will be
terminated;
(f) performing obligations under or in connection with the provision of our goods or services to our clients;
(g) facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part
of our organisation, or corporate restructuring process; and
(h) facilitating our compliance with any laws, customs and regulations which may be applicable to us.
9. 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).
 
WITHDRAWING CONSENT BY JOB APPLICANTS
10. 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. If you are a job applicant, 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.
11. 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.
12. 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 10 above.
13. 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.
 
ACCESS TO AND CORRECTION OF PERSONAL DATA
14. If you wish to make 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 to our Data Protection Officer at the contact details provided below.
15. 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.
16. 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).
17. 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
18. 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.
19. 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.
 
ACCURACY OF PERSONAL DATA
20. 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.
 
RETENTION OF PERSONAL DATA
21. 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.
22. 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 SINGAPORE
23. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so,
we will obtain your consent for the transfer to be made 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.
 
DATA PROTECTION OFFICER
24. 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
348 Jalan Boon Lay Singapore 619529
Email Address: DPO@hanwell.com.sg
Contact Number: 6268 4822
 
EFFECT OF POLICY AND CHANGES TO POLICY
25. 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.
26. 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 policy was last updated. Your continued
employment and participation in our recruitment process constitute your acknowledgement and acceptance
of such changes.