EMPLOYEES DATA PRIVACY NOTICE
At ZENIKA PTE. LTD. (“Zenika” or “we”), we respect the privacy and confidentiality of personal data. We are committed to implementing policies, practices and processes to comply with the Personal Data Protection Act 2012 (“PDPA”). The PDPA sets out rules for governing the collection, use and disclosure of personal data by organisations in Singapore.
This notice (“Notice”) sets out the manner in which we may collect, use, disclose or otherwise process Personal Data of employees, job applicants and internal stakeholders in accordance with the 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 only to Personal Data provided by or collected from employees, job applicants and internal stakeholders in Singapore and is not intended to describe data handling procedures for Personal Data collected by other linked websites or business partners.
1. DEFINITIONS
For the purposes of this Notice:
“Personal Data” means data, whether true or false, that is capable of identifying an individual, whether on its own or in conjunction with other data to which we have or are likely to have access. Depending on the nature of your interaction with us, Personal Data may include, without limitation:
- 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;
- 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).
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
2. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
2.1 This section lists the ways in which Personal Data are collected, used, stored and disclosed in your course of employment/engagement with us.
2.2 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. We will 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).
2.3 You will be deemed to have consented to the collection, use, disclosure and storage of your Personal Data when you voluntarily provide your Personal Data to the HR department for the stated purpose and it is reasonable to do so.
2.4 We will only collect, use or disclose Personal Data that we consider to be reasonably necessary for our functions and activities. We collect two types of Personal Data:
- personal information (such as name, race, mobile/residential telephone number, email address and residential address); and
- aggregate or “combined” information: information received from third-party sources that we combine with other personal information that we have collected. If we receive personal information about you from a third party, we will take reasonable steps to ensure that the third party from whom we receive such information can validly give consent to the collection, use and disclosure of your information.
2.5 We may collect your Personal Data in one or more of the following ways or circumstances:
- while interacting with you, or via a third party who has been duly authorised by you to disclose your Personal Data (such as publicly-available sources, social media platforms, and providers of third-party products or services or third party service providers);
- at the time of recruitment and during the selection process;
- at the time of confirmation of employment;
- through external collection points (i.e. job applications/job portal);
- via outsourced services (i.e. recruitment agency);
- when you submit your Personal Data to us for any other reason related to the ordinary course of business operations.
3. PURPOSE OF COLLECTION
3.1 We may collect, use and/or disclose your Personal Data for one or more of the following purposes:
- for recruitment and confirmation of employment;
- performing obligations under or in connection with your contract of employment with us, including payment of remuneration and tax;
- all administrative and human resources related matters within our organisation, including administering payroll, granting access to our premises and computer systems, processing leave applications, administering your insurance and other benefits, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource policies;
- 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 or continued employment/appointment 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;
- 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; and
- facilitating our compliance with any laws, customs and regulations which may be applicable to us.
3.2 We may disclose your Personal Data to third party service providers acting on our behalf, such as payroll providers, tax agent, insurance companies. While these third parties have access to some of your Personal Data, the information is limited to what they need to know to do their jobs.
3.3 The purposes listed above 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 a contract with you).
4. CONSENT
Unless otherwise authorised under the PDPA or any other applicable law, we will not collect, use or disclose any Personal Data without your consent. We will take reasonable steps to highlight the relevant purpose, by appropriate means, at the point or time of collection of Personal Data.
5. RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
5.1 In compliance with the PDPA, we may collect, use or disclose your Personal Data without your consent for the legitimate interests of Zenika or another person. In relying on the legitimate interests exception of the PDPA, we will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
5.2 In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
- fraud detection and prevention;
- detection and prevention of misuse of services; and
- collection and use of personal data on company-issued devices to prevent data loss.
5.3 The purposes listed in the above clause 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.
6. WITHDRAWAL OF CONSENT
6.1 The consent you provided for the collection, use and disclosure of Personal Data will remain valid until such time you withdraw it in writing.
6.2 You may inform us, at any time, that you wish to withdraw your consent and do not want Zenika or the third party service providers to contact you, you may do so by submitting a written request to our Data Protection Officer at the contact details provided below.
6.3 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue to employ/engage you and we will, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform our Data Protection Officer.
6.4 Upon receipt of a written request to withdraw consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for the 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 will seek to process and effect such a request within thirty (30) working days of receiving it.
6.5 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.
7. ACCESS TO AND CORRECTION OF PERSONAL DATA
7.1 If you wish to make (a) an access request for access to a copy of your Personal Data 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, you may submit a written request to our Data Protection Officer at the contact details provided below.
7.2 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.
7.3 We will respond to such access request within thirty (30) working days. If we are not able to respond to your access request within thirty (30) days after receiving the access request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to the request. If we are unable to provide you with any Personal Data or to make the requested correction, we will inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
7.4 We are not required, under the PDPA, to provide access and correction to Personal Data in certain exempted situations as set out in the PDPA.
8. PROTECTION OF PERSONAL DATA
8.1 The safety of your Personal Data is paramount for us. 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 minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, and security review and testing performed regularly.
8.2 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.
9. ACCURACY OF PERSONAL DATA
9.1 We generally rely on Personal Data provided by you (or your authorised representative).
9.2 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 the HR department or the Data Protection Officer in writing at the contact details provided below.
10. RETENTION OF PERSONAL DATA
10.1 We may retain your Personal Data for as long as it is necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws.
10.2 We will cease to retain your Personal Data or remove the means by which the Personal 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 is no longer necessary for legal or business purposes.
10.3 We may retain some of the Personal Data for research or statistical purposes. In such a case, the Personal Data will be anonymised.
11. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
Personal Data may be transferred to Zenika France or other countries outside of Singapore as detailed in the Notice. We take steps to ensure that Personal Data, when transferred, continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
12. QUERIES AND COMPLAINTS
If you have any query or wish to make a complaint about how Zenika handles your Personal Data, please contact our Data Protection Officer. The Data Protection Officer must treat such queries and complaints seriously and deal with them confidentially and within reasonable time. Any query or complaint should include, at least, the following details:
- full name and contact information of the employee;
- nature of the query or complaint: and
- brief description of the query or complaint.
13. DATA PROTECTION OFFICER
You may contact Zenika’s Data Protection Officer if you have any enquiries or feedback on our Personal Data protection policies and procedures; or if you wish to make any request, in the following manner:
Name of DPO : Timothee Dufresne
Contact No. : +65 8732 8817
Email Address : timothee.dufresne@zenika.com
Name of DPO : Carol Pang
Contact No. : +65 9114 4561
Email Address : carol.pang@zenika.com
14. EFFECT OF NOTICE AND CHANGES TO NOTICE
14.1 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.
14.2 We may from time to time update this 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.
15. GOVERNING LAW
This Notice is governed by and construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Notice including any question regarding its existence, validity or termination, will be referred to and finally resolved by the Courts of Singapore.
Effective date : January 01, 2025
Last updated : March 14, 2025
