Your privacy is important to us. This Data Protection Policy outlines how your Personal Data will be collected, used, disclosed, managed, handled or otherwise process by Mills Recruitment Pte Ltd, (hereinafter collectively referred to as “Mills Recruitment”, “we”, “our” or “us”) in accordance with the Personal Data Protection Act 2012 (“PDPA”).

This Privacy Policy applies to all 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.

Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we may collect, use and/or disclose your Personal Data.

This Privacy Policy supplements but does not supersede nor replace any other consents which you may have previously provided to us, nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your Personal Data.

We may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements.

By accessing our website and/or engaging our services, you are deemed to have agreed to the terms of this Privacy Policy as amended from time to time.

A. DEFINITIONS

1. In this Data Protection Policy:-

“Authority” means relevant governmental and/or regulatory authorities, whether in Singapore or abroad which includes without limitation any judicial, administrative or regulatory body, any government or public or government agency, instrumentality or authority, any domestic or foreign tax, revenue, fiscal or monetary authority or agency, securities or futures exchange, self-regulatory organization, trade repositories, central counterparties, court, central bank or law enforcement body or any agents thereof, having jurisdiction over Mills Recruitment;

“Personal Data” refers to any data, whether true or not, about an individual 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, including data in our records that may be updated from time to time;

“Services” means the recruitment and Candidate placement services provided by Mills Recruitment; and

“you” or “Candidate” means a person who (a) has contacted us through any means to find out more about our Services; or (b) a person who may or has entered into a contract with us for the provision of Services.

B. PERSONAL DATA

2. Depending on the nature of your interaction with us, some examples of Personal Data which we may collect from you include your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, network data; and (c) any other information you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

3. In compliance with the PDPA and our commitment to protect Candidates’ Personal Data, Mills Recruitment will cease to collect, process, or use full NRIC numbers during our screening and job application process. KINDLY ENSURE THAT YOUR RESUME PROVIDED TO US DOES NOT CONTAIN YOUR FULL NRIC NUMBER AND FULL HOME ADDRESS DURING YOUR JOB APPLICATION. You are only required to state the last five digits of your NRIC Number e.g. “3697E”.

C. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

Collection

4. We generally do not collect your Personal Data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your Personal Data to us (your “authorised representative”) 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.

5. 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).

Use

6. However, Mills Recruitment may collect, use and/or disclose Personal Data that Candidates provide to us for the following purposes:

(a) job applications, matters relating to your employment with Mills Recruitment, and any other related purposes;

(b) submitting resumes to our clients for job placement;

(c) communicating with you to inform you of changes and updates or other relevant administrative information;

(d) verification of your identity;

(e) responding to your queries and requests and handling complaints;

(f) fulfilling referral requests;

(g) conducting market research for statistical profiling and other purposes to understand and determine demographics for us to review, develop and improve the services which we are providing to you;

(h) applying for and all matters Group Medical Insurance Policies;

(i) our marketing initiatives (including without limitation receiving our Electronic Direct Mailers – EDM, newsletters which you have signed up to receive or information of any existing/new services and products) and branding activities (including without limitation photographs or written or video/audio recordings of your quotes and testimony for media pitching, press releases and Mills Recruitment’s internal publications and broadcasts);

(j) Work Pass Application and any other passes (Airport Pass, secured premise or worksite Pass etc) that you may require during your employment with us;

(k) archival of documents and records in both electronic and physical form for record-keeping purposes for up to five (5) years provided that Personal Data therein in redacted;

(l) preventing, detecting, and investigating crime, including fraud and any form of financial crime, and analysing and managing other risks;

(m) employment training and Training Grant Application;

(n) compliance with any applicable local or foreign statute, rule, law, regulation, judgment, decree, directive, code of practice, guideline, administrative requirement, sanctions regime, court order, agreement between Mills Recruitment company and any Authority, agreement or treaty between Authorities, international guidance and internal policies or procedures, which may apply to any Mills Recruitment company or which any such company is subject to;

(o) to assist in or with law enforcement and investigations by any Authority or to comply with any request from an Authority; and

(p) subject to applicable law, any other purposes which may be required from time to time during your employment with us or using our Services.

Accuracy of data

7. You should ensure that all Personal Data submitted to us is correct, accurate and complete. You must update us promptly of all changes to the information provided to us. Failure on your part to do so may result in our inability to provide you with the Services.

8. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (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 us to enforce our rights under any contract with you).

Disclosure of Personal Data

9. Your Personal Data will be protected and kept confidential but, subject to the provisions of any applicable law, may be disclosed:

(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you;

(b) our corporate clients, to process your job applications.

(c) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 6 above for us (including but not limited to mailing, information technology, data processing, storage and archival);

(d) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres, whether in Singapore or otherwise.

(e) our professional advisers such as our auditors and lawyers;

(f) any other person in connection with the purposes set forth above.

D. COOKIES

10. We may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on our websites and common entry and exit points into our websites.

11. We use “cookies”, where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.

12. The Aggregate Information collected is used to assist us in analysing the usage of our websites and improving our websites. Should you wish to disable the cookies associated with these technologies; you may do so by changing the settings on your browser. However, you may not be able to enter certain parts of our websites.

E. THIRD-PARTY SITES

13. Our website may contain links to other websites operated by third parties, and we are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third-party websites. Some of these third-party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable Privacy Policy of the third party to determine how they will handle any information they collect from you.

F. WITHDRAWING YOUR CONSENT

14. The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw 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 Data Protection Officer at the contact details provided below.

15. 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 your request within ten (10) business days of receiving it.

16. Whilst we respect your decision to withdraw your consent to any or all use or disclosure of your Personal Data, please note that depending on the nature and scope of your request, we may not be in a position to continue providing Services to you or administer any contractual relationship in place and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above. Such withdrawal may also result in the termination of any agreement you may have with us.

17. 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. Notwithstanding your request to withdraw your consent, we may nonetheless retain some Personal Data to the extent one or more of the purposes for which it was collected remains valid and for other legal or business purposes for which retention may be necessary.

G. ACCESS TO AND CORRECTION OF PERSONAL DATA

18. 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 about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

19. 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.

20. We will respond to your request as soon as reasonably possible. 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 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).

H. PROTECTION OF PERSONAL DATA

21. 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 our authorised third party service providers and agents only on a need-to-know basis.

22. 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.

I. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

23. We generally do not transfer your Personal Data to countries outside of Singapore. 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.

J. EFFECT OF PRIVACY POLICY AND CHANGES TO PRIVACY POLICY

24. This Privacy Policy applies in conjunction with any other policiess, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.

25. We may revise this Privacy Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

K. DATA PROTECTION OFFICER

26. If you have any questions or complaints relating to the collection, use or disclosure of your Personal Data, or if you wish to know more about our data protection policies and practices, or if you wish to make any request, please contact our Data Protection Officer in the following manner:

[email protected]

+61 448 941 832

L. OPT-OUT POLICY FOR NEWSLETTERS / MARKETING MATERIALS

27. Mills Recruitment may from time to time send you newsletters, job openings and marketing materials based on the personal information and data that you have provided us. Suitable measures are implemented to allow you to “opt out” of receiving such materials. You may choose to sign up or unsubscribe for such materials by clicking on the automatic link appearing in each newsletter.