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Data Protection Policy

JC Howe International (JCH) respects the privacy of the personal information and data of job applicants who proactively write to us, respond to specific job opportunities that may be posted on job search portals, and/or potential candidates whom we may contact (i.e. “headhunt”) for prospective job opportunities – present or in the future.

Definitions

For the purposes of this Policy, the following terms, unless elsewhere defined in this Policy, shall have the following meanings:

"Act"	Means the Personal Data Protection Act 2012
"DPO"	Means the data protection officer appointed by JCH pursuant to the Act
"Laws"	Means the Act, other Statutes, regulations made thereunder, and any other applicable laws, regulations, guidelines, directives, codes of practice or where the context so requires the order or other lawful request made by any Public Agency
"JCH"	Means JC Howe International Pte Ltd
"Policy"	Means this JCH Data Protection Policy, as may be amended or supplemented by JCH at its discretion from time to time
"Person"	Means any individual to whom the Act applies and includes an individual job applicant and/or prospective candidates
"Personal Data"	Means personal data of a Person that JCH collects, uses or discloses which includes: •  Name, address, telephone number and e-mail address; •  NRIC, passport or other equivalent identification number including photograph or video image •  Education history •  Occupation, employment history and salary •  Bank account information
"Public Agency"	Means any Government body, including any ministry, department, agency (including law enforcement agencies) or organ of State, any judicial or quasi-judicial body or disciplinary, arbitral or mediatory body appointed under any written law in Singapore or any statutory body established under a public Act

A. Deemed Consent

Persons are deemed to have given their consent for the collection, use and disclosure of Personal Data in the following circumstances:

1. When the Person voluntarily provides his/her Personal Data to JCH
   
2. When the Person is aware of the purposes for which he/she is providing his/her Personal Data to JCH
   
3. In any other circumstance where consent is deemed under the Act

B. Limiting Collection, Use and Disclosure of Personal Data

1. JCH collects Personal Data primarily from Persons who are potential candidates for the identified purpose of presenting job opportunities and for matching our clients' recruitment needs with the relevant work experience of potential candidates.
   
2. JCH may use Personal Data to conduct research and analysis.
   
3. JCH will not disclose Personal Data to other persons or entities for advertising, promotion or marketing of such other party's products and services. JCH will not sell for payment the Personal Data to anyone for any marketing or commercial purpose.

C. International Transfer of Personal Data

Personal Data may be accessed or disclosed in countries outside Singapore when Persons are being considered for job opportunities outside Singapore. In such cases, JCH will take appropriate steps to ensure the same level of protection of Personal Data outside Singapore.

D. Retention of Personal Data

JCH will collect and retain Personal Data via the procedures described in this Policy for as long as such Persons remain our potential candidates or for as long as it is necessarily required or relevant for business or legal purposes.

E. Withdrawal of Consent

1. At any time, Persons are able to withdraw their consent to our continued use and disclosure of Personal Data. Such withdrawals should be made formally in writing to the Office of the DPO.
   
2. If consent is withdrawn, the Person acknowledges that JCH will no longer be able to present prospective job opportunities – present or future – to the Person.
   
3. Persons may write in to the Office of the DPO for more information regarding the implications of withdrawing consent.

F. Protection of Personal Data

To the extent required by the Act, JCH shall protect Personal Data in its possession or under its control against risks of unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction, through reasonable and appropriate security measures.

G. Accuracy and Correction of Personal Data

1. To the extent required by the Act, JCH will use reasonable efforts to ensure that the Personal Data it uses is sufficiently accurate and complete to minimize the possibility that incorrect Personal Data may be used to make a decision that impacts the Person to whom the Personal Data relates, or if such Personal Data is likely to be disclosed to a third party. However, you acknowledge that there may be circumstances where JCH is entitled to assume such accuracy and completeness, in accordance with Laws.
   
2. JCH encourages Persons to inform us when there are any changes to the Personal Data which they have provided to ensure that JCH has the most current, accurate and complete information. Under request by a Person, JCH, may in accordance with the Act, correct or complete any Personal Data found to be inaccurate or incomplete as soon as practicable. Any unresolved differences as to accuracy or completeness of Personal Data shall be noted in the Person's records. Save as otherwise required under the Act, the Person may only correct any Personal Data which the Person has provided to JCH. JCH reserves the right not to correct Personal Data where permitted under the Act.

H. Access to Personal Data

1. To the extent required by the Act, upon request, JCH shall provide a Person with an account of his/her Personal Data which is in JCH's possession or control. Such information requested for shall be provided within a reasonable time and at a reasonable cost to the Person making the request.
   
2. To the extent required by the Act, upon request by a Person, JCH shall provide information relating to how the Person's Personal Data has been or may have been used or disclosed within a year before the date of such request. Such information requested for shall be provided within a reasonable time and at a reasonable cost to the Person making the request.
   
3. Subject to the Act, JCH may not be able to provide access to all of the Personal Data that it holds about a Person. For example, JCH may not provide access to Personal Data if such provision could reveal Personal Data about another person, if such information is subject to legal privilege or if such provision will be contrary to national interest. If access to Personal Data cannot be provided, the reasons for denying such access will be provided upon request to the extent permitted under Laws.
   
4. Persons may seek access to their Personal Data by writing to the Office of the DPO.

I. Data Protection Officer (DPO)

The DPO may be contacted at:

The Office of the Data Protection Officer
JC Howe International Pte Ltd
1 Scotts Road, #24-05 Shaw Centre
Singapore 228208

Email: [email protected]

J. Procedures and Practices

JCH has implemented the following procedures to give effect to this Policy:

1. Implementing procedures to protect Personal Data and to oversee compliance with the Act including means to access and/or correct Personal Data and to facilitate withdrawal of consent
   
2. Establishing procedures to receive and respond to inquiries or complaints in relation to Personal Data
   
3. Training and communicating to employees about this Policy
   
4. Notifying changes to this Policy on the JCH website

K. General

JCH may revise and/or amend and/or supplement this Policy at its discretion from time to time. Such changes will be published on this website. Persons are advised to check back periodically to ensure that they are aware of any changes. To the fullest extent permissible under Laws, you agree to be bound by the prevailing terms of this Policy.

EFFECTIVE DATE: 2 July 2014