This Data Protection Notice (“Notice”) of NTUC First Campus Limited, a company limited by guarantee registered in Singapore (“NFC”), and its Affiliates (each an “Affiliate”). The terms “we”, and “our” in this Policy refer to NTUC First Campus Limited, and/or each of the Affiliates. For the purpose of this Policy, “Affiliate” means the organisations as listed on https://www.ntucfirstcampus.com. This Notice sets out the basis upon which we may collect, use, disclose or otherwise process personal data of personnel and job applicants in accordance with the Personal Data Protection Act 2012 (“PDPA”). 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 full-time, part-time and temporary employees, contract workers and indirect staff of NFC, such other persons engaged by us to perform duties or functions for us,  interns and trainees working at or attached to us (collectively referred to as “personnel”) as well as persons who have applied for any such position with us (“job applicants”), and all references to “employment” shall apply equally to any and all Personnel . 

1. Collection, Use and Disclosure
    
   • We generally collect personal data that you have knowingly and voluntarily provide in the course of or in connection with your employment or job application with us, 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 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). In exceptional circumstances, we may rely on consent given by another individual who is authorised to provide the consent on your behalf.
     
   • If you are a job applicant, personal data which we may collect includes, without limitation, your:
     • name or alias, gender, date of birth, nationality, and country and city of birth;
     • mailing address, telephone numbers, email address and other contact details;
     • resume, educational qualifications, professional qualifications and certifications and employment references;
     • employment and training history;
     • work-related health issues and disabilities;
     • photographs; and
     • any additional information provided to us by you for the purpose of job application
   • If you are an employee, personal data which we may collect in the context of your employment with us includes, without limitation, your:
     • name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country and city of birth;
     • mailing address, telephone numbers, email address and other contact details;
     • employment and training history;
     • salary information and bank account details;
     • details of your next-of-kin, spouse and other family members; (f) work-related health issues and disabilities;
     • records on leave of absence from work;
     • photographs and other audio-visual information;
     • performance assessments and disciplinary records; and
     • any additional information provided to us by you as a job applicant (that is, prior to being engaged as an employee) and in the course of your employment/engagement of service with us
       
       
2. Collection, Use and Disclosure
   
   
   • We generally collect personal data that you have knowingly and voluntarily provide in the course of or in connection with your employment or job application with us, 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 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). In exceptional circumstances, we may rely on consent given by another individual who is authorised to provide the consent on your behalf.
     
     
   • Our website and applications may also contain or involve certain technologies that automate the collection of data (including personal data). These technologies may include and not limited to cookies, web beacons and web analytics. If you do not wish to have your data collected through such technologies you may disable the operation of these technologies on your devices (where possible), or you may refrain from using our websites and applications.
     
     
3. Purposes
   
   
   • If you are a job applicant, your personal data will be collected and used by us and we may disclose your personal data to third parties where necessary, for a number of business purposes, including but not limited to:
     • assessing and evaluating your suitability for employment in any current or prospective position;
     • verifying your identity and the accuracy of your personal details and other information provided;
     • notifying you the status of your application and/or potential job opportunities;
     • handling of all administrative and human resources matters within our organisation in the event that your application is successful;
     • disclosure to relevant authorities in accordance with the request or requirements of the relevant authorities;
     • Government and other regulatory reporting;
     • knowledge management within the organization and internal reporting or audit purposes;
     • business planning and statistical analysis;
     • for contact tracing purposes under extraordinary circumstances;
     • facilitating our compliance with laws, customs and regulations applicable to us; and
     • for any other reasonable purposes related to you as a job applicant.
       
   • If you are an employee, your personal data will be collected and used by us and we may disclose your personal data to third parties where necessary,  for a number of business purposes, including but not limited to:
     • performing obligations under or in connection with your contract of employment with us, including scheduling work activities and projects undertaken by the organization, employee performance management and professional development, etc ; 
     • all administrative and human resources related matters within our organisation, including administering payroll, claims reimbursements, accounting for tax purposes, granting access to our premises and computer systems, processing leave applications and consumption of employment benefits, facilitating corporate insurance coverage and other benefits, investigating any acts or defaults (or suspected acts or defaults), applying for work permits at the Ministry of Manpower if needed, developing human resource policies, administer business travel and other corporate events where applicable;
     • managing and terminating our employment relationship with you, including monitoring your internet access and your use of our intranet email to investigate potential contraventions of our internal or external compliance regulations, and resolving any employment related grievances; 
     • assessing and evaluating your suitability for employment/appointment,continued employment/appointment or redeployment in any position within our organisation;
     • ensuring business continuity for our organisation in the event that your employment with us is or will be terminated;
     • publicity, external and internal marketing purposes, where applicable;
     • Government and other regulatory reporting;
     • knowledge management and training for staff;
     • for internal reporting/accounting or audit purposes; .
     • business and market development, where applicable;
     • registrations and submissions with relevant government or regulatory authorities, and financial institutions (e.g. bank signatories), as necessary;
     • for security and access controls, safety surveillance and monitoring and reporting purposes;
     • for emergency signatories and for contact tracing purposes;
     • performing obligations under or in connection with the provision of our goods or services to our clients; 
     • facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organisation, or corporate restructuring process; 
     • facilitating our compliance with any laws, customs and regulations which may be applicable to us; and  
     • for any other reasonable purposes related to you as a job applicant.
       
       
   • We may disclose your personal data:
     • with your consent, where such disclosure is required in connection with the purposes listed above;
     • 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
     • with your consent, to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in Paragraphs 3.1 and 3.2 above for us. Any third parties engaged by us will be contractually bound to keep all personal data confidential.
       
       
   • When using your personal data to contact you for the above purposes, we may contact you via mail, e-mail, text message, telephone, pop-up notifications (when you are using our applications), or any other means.
     
     
4. Withdrawing Consent by Job Applicants
   
   
   • 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 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 Data Protection Officer at the contact details provided in clause 10.1.
     
     
   • 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 clause 4.1 above.
     
     
   • Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
     
     
5. Access to and Correction of Personal Data
   
   
   • 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 in writing or via email to our Data Protection Officer at the contact details provided in clause 10.1.
     
     
   • 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.
     
     
   • Please note that 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 organisation has on record, if the record of your personal data forms a negligible part of the document.
     
     
6. Protection of Personal Data
   
   
   • 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.
     
     
   • While we take reasonable precautions to safeguard your personal data in our possession or under our control, you should be aware that no method of transmission over the Internet or method of electronic storage is completely secure. We cannot be held responsible for unauthorised or unintended access that is beyond our control, including hacking or cybercrimes. We also do not guarantee that our websites and applications are invulnerable to security breaches, or that your use of our websites and applications is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities.
     
     
7. Accuracy of Personal Data
   
   
   • We generally rely on personal data provided by you (or your authorised representative). 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 Data Protection Officer in writing or via email at the contact details provided clause 10.1.
     
8. Retention of Personal Data
   
   
   • We keep your personal data only for so long as we need the data to fulfil the purposes we collected it for, and to satisfy our business and legal purposes, including audit, accounting,reporting requirements, or as permitted by applicable laws.
     
     
   • 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.
     
     
9. Transfer of Personal Data outside Singapore
    
   • Where applicable, your Personal Data may be stored in external servers located overseas. In addition, as described above, in the course of our business operation needs, we may be required, from time to time, to transfer your Personal Data with and between our related corporations and/or organisations and their affiliates, and third party service providers, some of which may be located in countries outside of Singapore. For example, your personal data stored in the Software may be transferred overseas for support functions. The personal data transfer will be in accordance with requirements prescribed under the PDPA or applicable data protection law to ensure that organisation provide a standard of protection to personal data. Rest assured, where we disclose personal data to a third party in another country, we put safeguards in place to ensure your personal data remains protected.
     
     
   • However, if we do so, we will obtain your consent for the transfer to be made and 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.
     
     
10. Data Protection Officer Contact Information
    
    
    • You may contact Data Protection Officer (dpo@ntucfirstcampus.com), or write in to us at (NTUC First Campus Limited, 229 Mountbatten Road, #02-08, Mountbatten Square, Singapore 398007) if you have any enquiries, request or feedback on our personal data protection policies and procedures.
      
      
11. Response Timeline
    
    
    • When you submit your request to us according to Paragraphs 3.1 or 4.1, we will respond to your request within thirty (30) business days. 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 process 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).
      
      
12. Effect of Notice and Changes to Notice
    
    
    • This Notice applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
      
      
    • We may revise this Notice 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 Notice was last updated. Your continued employment and participation in our recruitment process constitute your acknowledgement and acceptance of such changes.

Last updated: 10 November 2024

Effective date: 01 January 2025