Privacy Policy Draft

PURPOSE

1) The Personal Data Protection Policy document is to document how Tele-centre Services Pte Ltd (“Tele-centre”) comply with the provisions of the Personal Data Protection Act (“PDPA”) 2012 of Singapore.

2) This document sets out the following:

a) Tele-centre’s policies on how we manage your Personal Data;

b) The types of Personal Data we collect, use, disclose, process and/or retain;

c) How we collect, use, disclose, process and/or retain your Personal Data; and

d) The purpose(s) for which we collect use, disclose, process and/or retain your Personal Data.

DEFINITIONS OF PERSONAL DATA

3) The PDPA defines Personal Data as “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 the organization has or is likely to have access”.

4) It is important to note that the PDPA does not apply to business contact information. Business contact information refers to individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by him or her solely for his or her personal purposes.

PERSONAL DATA INVENTORY

5) Tele-centre has the following personal data in our custody:

a) Personal Data of employees or job candidates. These includes but not limited to the following:

  • Name, NRIC, passport, FIN or other identification number, birth date, telephone number(s), residential, business and/or residential addresses and email address;
  • Health, financial, criminal and any other information provided;
  • Employment history, education background, and income levels;
  • Medical report if you are sent for a medical review;
  • Directorships, connections or interest in any external organizations/entities;
  • Your photos, audio recording, video footages from our office CCTVs and fingerprint biometric;
  • Personal Data of family members, such as next of kin, spouses, and children;
  • Bank account number for salary credit; and
  • Any other information voluntarily provided by you.

b) Personal Data of individuals who we interact and engage on behalf of our Clients. These includes but not limited to the following:

  • Name, NRIC, passport, FIN or other identification number, birth date, telephone number(s), residential, business and/or residential addresses and email address;
  • Name, NRIC, passport, FIN or other identification number, birth date, contact number(s), residential, business and/or mailing addresses, email address and any other information specified by our Clients;
  • Name, NRIC, contact number, residential address and email address of family members;
  • Information relating to payments/Giro, such as CAN number of EZLink cards;
  • Any other ad-hoc Personal Data requested by Client that Tele-centre must follow up with individual;
  • Any Personal Data voluntary provided by Client.

COLLECTION OF PERSONAL DATA

6) Tele-centre collects Personal Data of our employees and job applicants that they knowingly and voluntarily provide through the following methods:

a) When a job applicant submits job application form together with resume via email or through Tele-centre’s website or any other job portals;

b) When a newly hired employee submits Employee Personal Data Form and register fingerprint biometric as part of onboarding;

c) When a recruitment agency sends resume of potential candidates for Tele-centre’s review;

d) When a job applicant submits Tele-centre’s job application form;

e) When a job applicant or employee interacts with Tele-centre’s employees such as Human Capital Department, with Interviewer or with immediate superior;

f) When a job applicant or employee responds to Tele-centre’s request for Personal Data; and

g) Recordings of all calls (for contact centre agents only); and

h) CCTV recordings of office premise.

7) If any individual chooses not to provide us with their personal data, depending on our relationship with this individual, Tele-centre may not be able to provide our services and/or products, process your job application, or follow-up regarding any complaints, feedback, queries, or requests received via our website or any other communication channels.

8) Tele-centre collect, use, disclose and/ or retain Personal Data of individuals or organizations who we interact and engage on behalf of our Clients through the following methods:

a) When an individual or organization knowingly and voluntarily provides their Personal Data when they interact with our Call Centre Operations or Service Centre Operations through walk-ins, phone, email, webchat, WhatsApp, direct mailers or any other form of communication channels.

USAGE OF PERSONAL DATA

9) Tele-centre collect, use, disclose and/ or retain Personal Data of our employees and job applicants for the following purposes:

a) To assist in any job-related enquiries;

b) To screen job applicants for job suitability;

c) To provide employment;

d) To enforce access control to our office premises and to record access to office premise as part of office security;

e) For attendance tracking;

f) To purchase corporate insurance;

g) To record all calls between call centre agents and callers as part of contractual obligations

h) To comply with applicable laws and regulations.

10) Tele-centre collect, use, disclose and/ or retain Personal Data of individuals who we interact and engage on behalf of our Clients for the following purposes:

a) To assist in enquiries;

b) To deliver contractual obligations;

c) To improve customer services, such as resolving complaints and perform service recovery.

DISCLOSURE OF PERSONAL DATA

11) Tele-centre may disclose Personal Data of our employees and job applicants for the following purposes:

a) To hospitals, clinics or insurance companies in connection with insurance claims;

b) To our professional advisers such as our auditors where necessary;

c) To relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any government authority;

d) To any other authorized person in connection with the purposes set forth above.

12) Tele-centre may disclose Personal Data of individuals who we interact and engage on behalf of our Clients for the following purposes:

a) Escalation to our Clients as part of our contractual obligations;

b) To relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any government authority;

c) To any other authorized person in connection with the purposes set forth above.

13) Tele-centre do not disclose Personal Data of our employees/job applicants or individuals who we interact and engage on behalf of our Clients, to any other country outside Singapore except in accordance with requirements indicated in the Personal Data Protection Act 2012 or as indicated in item 10 above.

WITHDRAWAL OF CONSENT

14) Employees/job applicants are able to withdraw their consent to Tele-centre’s continued use and disclosure of personal data as described in this Policy at any time. Such withdrawal should be made formally in writing to Tele-centre’s Data Protection Officer. Depending on the nature of the withdrawal of consent, Tele-centre may no longer be able to provide employment to the employee/job applicant.

15) Withdrawal of consent requests from individuals who we interact and engage on behalf of our Clients will be escalated to the respective Client for their follow up action.

ACCURACY OF PERSONAL DATA

16) Tele-centre takes all reasonable measures to ensure that Personal Data remains accurate, complete and up-to-date. These measures include but not limited to:

a) Maker and checker process by our Human Capital department when processing any employee records;

b) Random checks and audits on the Contact Centre Operations by their supervisors and Service Excellence Department.

17) Tele-centre will ensure any personal data it discloses to another organization is reasonably accurate and complete for the intended purposes.

PROTECTION OF PERSONAL DATA

18) Tele-centre is committed to safeguarding your Personal Data. We treat all personal data provided to us in strict confidence, and will only use your Personal Data in the manner set out in this Data Protection Policy.

19) Tele-centre takes reasonable steps to handle and to protect Personal Data as required under the Personal Data Protection Act (PDPA) and other relevant legislations. Examples of the security measures that we have are:

a) Computer safeguards and password-protected files to enhance the security of the Personal Data;

b) Access control enforcements on access to Personal Data;

c) Securing all electronic storage and transmission of Personal Data with appropriate security technologies;

d) All employees’ hardcopy personal files are maintained by the Human Capital Department under lock and key;

e) Tele-centre will regularly review and implement appropriate security measures when processing and retaining Personal Data.

RETENTION OF PERSONAL Data

20) Personal Data of employee will be retained for the duration of the employee’s employment with Tele-centre.

21) Personal Data of job applicants will be retained for up to twelve (12) months and five (5) years for ex-employees.

22) Personal Data of individuals who we interact and engage on behalf of our Clients will be retained based on the contractual agreement with our Clients.

COMPLAINTS PROCEDURE

23) If a job applicant or an employee of Tele-centre has reason to believe that his/her Personal Data has been misused by Tele-centre, the employee is advised to lodge a complaint with the Data Protection Officer who will handle the complaints in accordance with Tele-centre’s Complaints/Dispute Handling Flow.

24) Complaints from individuals who we interact and engage on behalf of our Clients will be escalated to the respective Client for their follow up action.

CONTACT US

25) You may contact our Data Protection Officer at DPO@tele-centre.com for the following requests:

a) To rectify any incorrect or out-of-date personal data previously provided to us;

b) To withdraw any consent previously given to us to collect and retain your personal data;

c) To access your Personal Data that you have provided to Tele-centre;

d) Enquiry or feedback on our Personal Data Protection Policies and Procedures.

NEW PURPOSE(S) FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

26) Tele-centre will notify any affected individual(s) in writing, to obtain their consent should Tele-centre collects, uses and disclose their Personal Data for new or different purpose(s) other than what these individual(s) have consented to.

OTHERS

27) Tele-centre may collect or analyze 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 website(s) and common entry and exit points into our website(s).

28) Tele-centre uses “cookies” to store and track Aggregate Information on website visitors who visited our website(s). Such cookies are used to track information such as the number of users and their frequency of use, profiles of users and their online preferences.

29) Tele-centre uses “cookies” to:

a) Track website traffic;

b) Perform analytics and statistics reporting on our website(s);

c) Improve on the contents of Tele-centre’s website(s).

30) Website visitors may disable the usage of “cookies” on their internet web browser. However, they are to note that this may affect the functionality of the website(s).