This Data Protection Notice ("Notice") sets out the basis upon which Konica Minolta Business Solutions Asia Pte Ltd ("BSA", "we", "us", or "our") may collect, use, disclose or otherwise process personal data of applicants in accordance with the Personal Data Protection Act 2012 ("PDPA") and all associated regulations and guidelines which may from time to time be issued by the Personal Data Protection Commission (PDPC) of Singapore. 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. This Notice applies to all persons who have applied for any employment, contract, internship or traineesh ip position with us ("applicant"). Terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits)
Personal DataIn this Notice, "personal data" means data, whether true or not, about 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.
2. Personal data which we may collect from job applicants includes, without limitation, your:
a. name or alias, gender, 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.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
Collection, Use and Disclosure4. We generally collect personal data that (a) has been provided to us voluntarily by you 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).
5. We may collect, disclose or use your personal data pursuant to an exception under the Personal Data Protection Act or other written law such as during the following situations:
a. To respond to an emergency that threatens your life, health and safety or of another individual; and
b. Necessary in the national interest, for any investigation or proceedings.
6. 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;
b. verifying your identity and the accuracy of your personal details and other information provided;
c. communicating with you regarding the status of your application and prospective positions;
d. all administrative and human resources related matters within our organisation, in the case where your application is successful; and
e. assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority.
7. We may disclose your personal data:
a. with your consent, where such disclosure is required in connection with the purposes listed above;
b. to comply with any applicable laws, regulations, codes of practice, guidelines or rules (e.g. in an emergency or when we receive a subpoena to disclose your personal data); or
c. with your consent, to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in Paragraph 2 above for us. Any third parties engaged by us will be contractually bound to keep all personal data confidential.
8. You have the right of choice regarding the collection, usage and disclosure of your personal data. If you choose not to provide us with any of your personal data requested in this form, you may do so by indicating in the relevant field. Whilst we respect your decision, 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 continuing to process your job application. Should we not be able to respond to your request within thirty (30) days after receiving your 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 carry out your request, 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).
Withdrawing Your Consent
9. 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 your 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 Human Resources Department at the contact details provided below.
10. Depending on the complexity of the request and its impact to our relationship with you, we will cease (and instruct any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data within ten (10) business days of our receipt of your request, unless required or authorised under applicable laws. Should we require more time to give effect to a withdrawal notice, we will inform you of the time frame by which the withdrawal of consent will take effect.
11. 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) if the withdrawal is proceeded with. We shall, i n 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 5 above.
12. 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.
13. If you wish to request (a) 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) to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Human Resources Department at the contact details provided below.
14. Before we accede to your access or correction request, we may need to verify your identity by checking identification document, and the legitimacy of your request.
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 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).
Protection of Personal Data17. 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 authorised third parties and agents only on a need-to-know basis.
18. When we disclose your personal data to third parties in line with the purposes mentioned in paragraph 7, we will ensure that they provide sufficient guarantees to us to have implemented the necessary security measures to protect your personal data.
19. However, 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 personal data and are constantly reviewing and enhancing our informa tion security measures.
Accuracy of Personal DataWe will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up-to-date.
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 Human Resources Department in writing or via email at the contact details provided below.
Retention of Personal Data21. 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.
23. We dispose of or destroy such documents containing your personal data in a secure manner when the retention limit is reached and it is reasonable to assume that the permitted purpose is no longer being served by their retention.
24. For unsuccessful job applicants, records will be disposed within 1 year of hiring decision being made. It will be disposed of in a secure manner immediately after the said retention period.
Cross-border Transfers of Personal Data25. We generally do not transfer your personal data to other jurisdictions. However, if we do so, we will obtain your consent for the transfer to be made and we 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, including entering into an agreement with the receiving party to accord similar levels of data protection as those in Singapore.
Human Resources Department and Data Protection Committee Contact Information26. You may contact our Human Resources Department at bsa-hr@gcp.konicaminolta.com or our Data Protection Committee at dataprotection.bsa@konicaminolta.com if you have any enquiry, feedback or complaint regarding our personal data protection policies and procedures, if you wish to make any request, or if you believe that information we hold about you is incorrect or out-dated.
Effective: 1 October 2022
Last updated: 1 August 2022