DenseLight Data Protection Policy
1.0 Data Protection
This Data Protection Policy sets out the basis upon which DenseLight 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 DenseLight possession or under DenseLight control, including personal data in the possession of organizations which DenseLight have engaged to collect, use, disclose or process personal data for the company business and legal purposes.
2.0 Application of this Policy
2.1 This Policy applies to all persons engaged in a contract of service with DenseLight (whether on a part-time, temporary or full-time basis) and interns and trainees working at or attached to DenseLight (collectively referred to as “employees”) as well as persons who have applied for any such position with DenseLight (“job applicants”), and all references to “employment” shall apply equally to internships and traineeships (as may be applicable).
3.0 Personal Data
3.1 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.
3.2 If the persons are a job applicant, the personal data which DenseLight may collect includes, without limitation, are:
(a) name or alias, gender, last 4 digit of the NRIC, 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
3.3 If the persons are an employee, personal data which DenseLight may collect in the context of employment with DenseLight includes, without limitation, are:
(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) performance assessments and disciplinary records; and
(j) any additional information provided to us by the person as a job applicant (that is, prior to being engaged as an employee).
3.4 Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
4.0 Collection, Use and Disclosure of Personal Data
4.1 DenseLight generally collect personal data that (a) the applicant/employee knowingly and voluntarily provide in the course of or in connection with the employment or job application with DenseLight, or via a third party who has been duly authorized by the applicant/employee to disclose the applicant/employee personal data to DenseLight (the applicant/employee “authorized representative”, which may include the job placement agent), after (i) applicant/employee (or the applicant/employee authorized representative) have been notified of the purposes for which the data is collected, and (ii) applicant/employee (or the applicant/employee authorized representative) have provided written consent to the collection and usage of his/her 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. DenseLight shall seek the applicant/employee consent before collecting any additional personal data and before using the applicant/employee personal data for a purpose which has not been notified to the applicant/employee (except where permitted or authorized by law).
4.2 If the person is a job applicant, his/her personal data will be collected and used by DenseLight for the following purposes and DenseLight may disclose your personal data to third parties where necessary for the following purposes:
(a) assessing and evaluating the applicant’s suitability for employment in any current or prospective position within the organization; and
(b) verifying the applicant’s identity and the accuracy of applicant’s personal details and other information provided.
4.3 If the person is an employee, his/her personal data will be collected and used by DenseLight for the following purposes and DenseLight may disclose the employee’s personal data to third parties where necessary for the following purposes:
(a) performing obligations under or in connection with your contract of employment with DenseLight, including payment of remuneration and tax;
(b) all administrative and human resources related matters within our organization, including administering payroll, granting access to our premises and computer systems, processing leaves applications, administering the insurance and other benefits, processing the 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 the employee, including monitoring his/her internet access and his/her use of DenseLight email to investigate potential contraventions of DenseLight internal or external compliance regulations, and resolving any employment related grievances;
(d) assessing and evaluating the employee’s suitability for employment/appointment or continued employment/appointment in any position within our organization;
(e) ensuring business continuity for our organization in the event that employee’s employment with DenseLight is or will be terminated;
(f) performing obligations under or in connection with the provision of DenseLight goods or services to DenseLight clients;
(g) facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of DenseLight organization, or corporate restructuring process; and
(h) facilitating DenseLight compliance with any laws, customs and regulations which may be applicable to DenseLight.
4.4 The purposes listed in the above clauses may continue to apply even in situations where the employee’s relationship with DenseLight (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 DenseLight to enforce its rights under any contract with the employee).
5.0 Withdrawing Consent
5.1 The consent that the job applicant provides for the collection, use and disclosure of his/her personal data will remain valid until such time it is being withdrawn by the job applicant in writing. If you are a job applicant, you may withdraw consent and request DenseLight to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request using the “Withdrawal Of Consent Request Form” in writing or via email to our Data Protection Officer or the Human Resource Manager.
5.2 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 ten (10) business days of receiving it.
5.3 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 the above clause.
5.4 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.
6.0 Access to And Correction of Personal Data
6.1 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 using the "Access Request Form" or "Personal Data Correction Form" in writing or via email to our Data Protection Officer.
6.2 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.
6.3 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).
6.4 If the amount of data collected is adequate enough, a one (1) year data will be provided to the requestor. 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 organization has on record, if the record of your personal data forms a negligible part of the document.
6.5 The data provided if applicable, will include the name of the third party which DenseLight have transact with using the applicant or employee personal data.
7.0 Protection of Personal Data
7.1 To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, DenseLight provide appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and/or use of a privacy filters to secure all storage and transmission of personal data and disclosing personal data both internally and to our authorized third party service providers and agents only on a need-to-know basis.
7.2 It should be noted, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, DenseLight strive to protect the security of the information and are constantly reviewing and enhancing DenseLight information security measures.
7.3 Disposal
7.3.1 DenseLight consider disposing physical media in a secure manner through Shredding processes (e.g. letters, documents and cards in paper form) or breaking them into two (e.g. read-only CDs and DVDs).
7.3.2 DenseLight is permanently destroying or removing electronic data in the unused electronic media (e.g. Hard drive, USB, Other storage device) by physically destroying it (e.g. by crushing, drilling or shredding) or with the use of specialized hardware appliances that cater for the destruction (e.g. a degausser machine produces a strong electromagnetic field that can destroy magnetically recorded data).
8.0 Accuracy of Personal Data
8.1 DenseLight generally rely on personal data provided by individual (or by the authorized representative). In order to ensure that the personal data is current, complete and accurate, an update of personal data is necessary by informing the Human Resource Department or the Data Protection Officer in writing or via email at the contact details provided below.
9.0 Retention of Personal Data
9.1 DenseLight may retain 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.
9.2 DenseLight will cease to retain the personal data, or remove the means by which the data can be associated with the individual, 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.
10.0 Transfers of Personal Data Outside of Singapore
10.1 DenseLight generally do not transfer the personal data to countries outside of Singapore. However, if do so, DenseLight will obtain the consent of the person involve for the transfer to be made and will take steps to ensure that the personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
11.0 Data Protection Officer
11.1 If you have any enquiries or feedback on our personal data protection policies and procedures; or if you wish to make any request please contact the Data Protection Officer;
Email Address: dpo@denselight.com
Alternatively, you may contact our Human Resource Department
Email Address: hr_recruitment@denselight.com
12.0 Effect of Policy and Changes to Policy
12.1 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 personal data.
12.2 DenseLight may revise this Policy from time to time without any prior notice. The individual who continued its employment and participation in DenseLight recruitment process constitute the acknowledgement and acceptance of such changes.