Data Protection Policy for Job Applicants
This Data Protection Policy (“Policy”) sets out the basis upon which SBS Transit Ltd and its subsidiaries, affiliates and related corporations (“we”, “us” or “our”) may collect, use, disclose or otherwise process the personal data of 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 recruitment purposes.
APPLICATION OF THIS POLICY
1. This Policy applies to all persons who have applied to be employed under a contract of service with us (whether on a temporary or permanent, or part-time or full-time basis, or as interns or trainees) (“job applicants”, “job applicant”, “you” or “your”).
2. As used in this Policy, “personal data” means data, whether true or not, about a person 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 about a job applicant 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;
- health condition or medical treatment which you have received, scheduled to receive, or will continue to receive, which may affect the provision of services under the contract of service applied for; and
- family members’ and employment referees’ personal data.
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
3. We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your 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, usage and disclosure of your personal data for those purposes, or (b) collection, use and disclosure of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
4. As 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 (“purposes”):
- assessing and evaluating your suitability for employment in any current or prospective position within the organisation;
- verifying your identity and the accuracy of your personal details and other information provided;
- communicating with you and/or any third parties (whose information is provided by you) in relation to your job application;
- conducting due diligence checks (such as age, identity, credit and background checks), including without limitation, identification/verification and information checks (where required by the Monetary Authority of Singapore), Anti-Money Laundering and Counter-Terrorism Financing Act 2006, FAA-N06 and other applicable legislation; and
- disclosure to relevant authorities in accordance with the request or requirements of the relevant authorities.
WITHDRAWING CONSENT BY JOB APPLICANTS
5. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or the purposes by submitting your request in writing via email to your respective recruiter and copy to SBST Data Protection officer @ email@example.com.
6. 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 seven (7) working days of receiving it, where possible.
7. 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 after your withdrawal of consent becomes effective. We shall, in such circumstances, notify you of the consequences of your withdrawal of consent before processing your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 5 above.
8. 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
9. 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
- a correction request to correct or update any of your personal data which we hold, you may submit your request in writing via email to your respective recruiter and copy to SBST Data Protection officer @ firstname.lastname@example.org.
We require a reasonable time period to effect a withdrawal request, and there should will not delay effecting such request without reasonable justification. In the absence of reasonable justification, we will endeavour to effect such request within thirty (30) days of a withdrawal request.
10. 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 before the expiry of the thirty (30) days, of the time we will require 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).
11. Please note that if you request for access to your personal data, we will only provide you with access to your personal data contained in our documents, and not to the entire documents themselves. In such cases, we will simply provide you with confirmation of the personal data that our organisation has on record, and not the documents.
PROTECTION OF PERSONAL DATA
12. 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, access control which is periodically reviewed, 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.
13. 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
14. 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 the relevant Human Resource staff in writing via email at the contact details provided.
Incomplete personal data provided will be not process for job application and job offer.
RETENTION OF PERSONAL DATA
15. We may retain your personal data for two years for consideration of future job opportunities (where applicable) from the date of submission of application.
16. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as we believe 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.
Last Updated: 5 April 2022