Job Applicant Data Protection Notice
Last updated: 20 January 2020
1. Scope of application
This data protection notice ("Notice") applies to the processing of personal data, which means information about an identifiable individual ("you"), that Pan Pacific Hotels Group Limited, its related corporations and ultimate holding company (collectively, "we", "us", "our" or "group") collects about candidates for employment. It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights and how to exercise them are set out in this Notice.
We also may provide you with additional information when we collect personal data where we feel it would be helpful to provide relevant and timely information.
2. What personal data we collect or receive from third parties (search/recruitment agencies, referees or background check providers)
- Personal identification and communication information: including your name, home address, phone number, email address, and immigration status;
- Application-related information: including curriculum vitae (CV), cover letter, employment history, education history, qualifications and skills, reference contact information, references, position preferences, willingness to relocate, desired salary, interests and aspirations, and background screening information if relevant; and
- Health and disability information: for example, information about your health and disabilities where we need to make any reasonable adjustments.
As well as collecting information from you directly, we receive information relating to you from recruiters and persons who you have named as referees.
3. Why we collect, use and store this personal data
We collect, use and store your personal data for the reasons set out below.
- As required to take steps which are necessary for us to enter into an employment contract with you:
- To make informed decisions on recruitment and assess your suitability for the role.
- To reimburse you for any agreed expenses incurred in the application process.
- Where necessary to comply with a legal obligation:
- As required to comply with applicable laws and protect our legal rights including, but not limited to, in connection with legal claims, (including disclosure of information in connection with legal process or litigation). If you are successful, this will include verifying whether you have the right to work in the country in which you are applying for a job with us and checking whether the information you have provided in the application is correct and carrying out other background checks as required by local law. We will provide more information about these checks before they are carried out.
- Where necessary for our legitimate interests, as listed below, and where our interests are not overridden by your data protection rights:
- to make informed decisions on recruitment, assess your suitability for the role and verify the details you have supplied (including background checks, which we will provide more information about before they are carried out);
- to communicate with you about the recruitment process and answer your queries;
- to keep you in mind for future roles;
- to improve our recruitment processes and activities;
- where permitted, to contact you about future career opportunities with us;
- to protect our legitimate business interests and legal rights, including, use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements.
Where we require you to provide personal data to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to complete your recruitment process, or to meet obligations placed on us. In all other cases, provision of requested personal data is optional. Where you do not provide the relevant data for in these circumstances, the consequences will be explained to you at the time.
4. Background screening
For certain positions, it will be necessary for us to verify the details you have supplied (for example, in relation to your identity, employment history, academic qualification and professional credentials) and to conduct pre-employment background checks (for example, in relation to previous criminal convictions to prevent and detect unlawful acts). The level of checks will depend on your role and will be conducted at as late a stage as is practicable in the recruitment process and often only after you have been selected for the position. If your application is successful, we will provide further information about the checks involved prior to completing such checks.
5. How we share your personal data
We will share your personal data with other members in our group for the purposes above.
Your personal data may also be shared with companies providing services under contract to us, such as background search firms, recruiters, medical professionals (for medical clearances), talent assessment providers to assess suitability.
Personal data will also be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the protection of our legitimate interests in compliance with applicable laws.
In the event that a part of our business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchaser's adviser and will be passed to the new owners of the business.
6. Your choices and rights
You have the right to ask us for a copy of your personal data; to correct, delete or restrict processing of your personal data; and to obtain the personal data you provide in a structured, machine readable format. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we do not have to process the data to meet a contractual or other legal requirement and in relation to processing for direct marketing purposes). Where we have asked for your consent, you may withdraw consent at any time. If you ask to withdraw your consent to us processing your data, this will not affect any processing which has already taken place at that time.
These rights may be limited, for example if fulfilling your request would unfairly reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you would like to exercise these rights, you can contact us using the details set out in section 10 below. If you have unresolved concerns you also have the right to complain to data protection authorities in the country where you live or work, or where you consider a breach of data protection law has occurred.
7. How long we retain your personal data
For successful candidates: We will retain your personal data for the purposes of the recruitment process and, once this process is finished, for an appropriate period so as to be able to deal with any requests, complaints or legal claims linked to the application process and for any further period we are required to keep your personal data under applicable law. After this period, we will take steps to delete your personal data or hold it in a form that no longer identifies you. If you become our employee, your personal data will become a part of your employee file and will be used later for the management of the employment relationship.
For candidates who are rejected or reject our offer: We will need to retain your personal data after the end of the recruitment campaign for an appropriate period so as to be able to deal with any requests, complaints or legal claims linked to the recruitment process and for any further period we are required to keep your personal data under applicable law. After this period, we will take steps to delete your personal data or hold it in a form that no longer identifies you. If you do not want us to keep your personal data for the purposes of potentially considering you for future positions, please let us know.
8. International transfers
Your personal data will be processed in or accessed from jurisdictions outside the European Economic Area ("EEA") by other members in our group or our parent company in Singapore and potentially third party providers in jurisdictions that do not have equivalent data protection laws to those in the EEA, such as the U.S. for the purposes outlined above.
When we transfer your data to our related corporations in Singapore or in other jurisdictions, we use an intra-company agreement containing European Commission-approved standard contractual clauses. When we transfer your data to third party service providers outside the our group we use European Commission-approved standard contractual clauses to safeguard the transfer, unless we transfer personal data to a third party that has implemented Binding Corporate Rules (developed by the European Union Article 29 Working Party) or which uses the EU-U.S. Privacy Shield, in which case we may rely on one of those mechanisms to safeguard the transfer.
9. Updates to this Notice
This Notice may be updated periodically. We will update the date at the top of this Notice accordingly and encourage you to check for changes to this Notice. On some occasions, we may also actively advise you of specific data handling activities or significant changes to this Notice as required by applicable law.
10. Contact Us
If you have any questions or feedback relating to your personal data or this Notice or would like to request access and/or corrections to your personal data records, you can approach us via the following channels:
- Call: +65 6808 1180
- Email: firstname.lastname@example.org
- Write to our Data Protection Officer at:
Data Protection Officer
7500 A Beach Road, #03-301 The Plaza, Singapore 199591
If you object to any or all use of your personal data, depending on the nature of your request, we may not be in a position to evaluate your application, enter into a contractual relationship with you or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with us. Our legal rights and remedies in such event are expressly reserved.