Privacy Policy

Data Protection for Freemansland Consultancy

This data protection policy applies to Freemansland Consultancy firm which are established in Singapore (“FMC” or “we”). This policy governs the collection, use and disclosure of personal data submitted to FMC, including through freemansland.co or through the Singapore pages of freemansland.co, and explains how we collect and handle personal data of individuals and comply with the requirements of the Personal Data Protection Act 2012 of Singapore and its regulation(s) (“PDPA”). In this policy, “personal data” shall have the meaning ascribed to it in the PDPA.

As a member of the FMC network, FMC shall also comply with the FMC network requirements in a number of ways, including through this policy. We also have other policies dealing with data protection, which may be connected with specific functions or business activities. For more information about: our (i) Recruitment Data Protection Policy, and (ii) our Marketing Data Protection Policy.

This policy does not override data protection requirements in the other above-mentioned policies to the extent those requirements are in addition to the requirements of this policy or protect personal data to at least the same standard as this policy. This policy overrides the data protection requirements in the other policies mentioned above to the extent this policy imposes additional requirements or requires a higher standard of protection of personal data. To avoid doubt, nothing herein shall require FMC to act in breach of applicable Singapore laws.

Main Data Protection Policy

Summary

We will collect, use or disclose personal data for reasonable business purposes only if there is consent or deemed consent from the individual and information on such purposes have been notified. We may also collect, use or disclose personal data if it is required or authorised under applicable laws.

Collection of Personal Data

We collect personal data from clients, customers, business contacts, partners, personnel, contractors and other individuals. Such personal data may be provided to us in forms filled out by individuals, face-to-face meetings, email messages, telephone conversations, through our websites or provided by third parties. If any individuals contact us, we may keep a record of that contact.

We collect these personal data when necessary for business purposes or to meet the purposes for which the individuals have submitted the information.

We will only collect, hold, process, use, communicate and/or disclose such personal data in accordance with this policy. If any party is acting as an intermediary or otherwise on behalf of a third party individual or supplying us with information regarding a third party individual (such as a friend, a colleague, an employee etc.), such intermediary party undertakes that you are an authorised representative or agent of such third party individual and that you have obtained all necessary consents from such third party individual to the collection, processing, use and disclosure by us of their personal data. Because we are collecting the third-party individual’s data from you, you undertake to make the third-party individual aware of all matters listed in this policy, preferably by distributing a copy of this policy to them or by referring them to our website.

Purpose of Personal Data

Freemansland Consultancy collects and processes personal data only for purposes that have been clearly explained to you. These purposes include the provision of services requested by you, communication with you, compliance with legal obligations, or other related business activities.

Your personal data will not be used for other purposes without your explicit consent unless such use is permitted or required by law. We commit to limiting the collection and use of personal data to what is necessary for these purposes.

Use of Personal Data

We use personal data for the following purposes:

• to provide our services

• to respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of the collection)

• to maintain contact with clients and other contacts

• to keep clients and other contacts informed of the services we offer, industry developments, service offerings, seminars and other events we are holding that may be of interest to them

• for general management and reporting purposes, such as invoicing and account management

• for recruitment purposes

• for purposes related to the employment of our personnel and providing internal services to our personnel

• all other purposes related to our business.

Any individual may choose to unsubscribe from mailing lists, or registrations or elect not to receive further marketing information from us by contacting our Data Protection Officer, or if we have contacted such individual by email, such individual may use the unsubscribe function in that email to notify us. Such requests will be processed within 28 days.

Protection of Personal Data

Freemansland Consultancy is committed to ensuring the security and integrity of your personal data. We have implemented appropriate technical and organisational measures to safeguard your data from unauthorised access, disclosure, alteration, or destruction. These measures include secure storage systems, encrypted data communications, and comprehensive employee training.

Disclosure of Personal Data to Third Parties

We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent, or when we have engaged third parties, such as data intermediaries or subcontractors, to assist with our firm activities. Any such third parties we engage will be bound contractually to keep all information confidential.

We may disclose personal data to other member firms in the Freemansland Consultancy network of firms where it is necessary (i) to meet the purpose for which such individual has submitted the information or (ii) to enable such individual to be provided with information at a later date which may be of relevance and interest to such individual based on the nature and purpose of such individual’s voluntary requests.  We may also transfer all data to a successor-in-interest to our business or assets.

Notification of Personal Data

We value transparency and strive to keep you fully informed about all matters related to your personal data. We will notify you promptly of any changes to our data protection policy. Additionally, in the event of a significant alteration to how we use your personal data, we will obtain your renewed consent.

Access to and Correction of Personal Data

Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA.

Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.

We may charge for a request for access in accordance with the requirements of the PDPA.

Withdrawal of Consent

Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given regarding our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised under applicable laws.

Accuracy of Personal Data

We will make a reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete.

Security and Protection of Personal Data

We have implemented generally accepted standards of technology and operational security to protect the personal data in our possession or under our control and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. All FMC personnel follow a network-wide security policy. Only authorised FMC personnel are provided access to personally identifiable information and these personnel have agreed to ensure confidentiality of this information. FMC’s policy is to use secure socket layer technology to protect credit card information submitted through web forms. This policy is also required for any fulfilment agents of FMC.

Data Breach of Personal Data

In the unfortunate event of a data breach, Freemansland Consultancy will promptly assess the risk to your rights and freedoms. If the breach poses a high risk, we will inform you without undue delay, as well as the Personal Data Protection Commission (PDPC) in Singapore. We will describe the nature of the breach, the likely consequences, and the measures taken or proposed to be taken to address the breach.

Retention of Personal Data

We will cease to retain personal data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.

Transfer of Personal Data outside of Singapore

We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA to ensure a standard of protection for personal data so transferred that is comparable to the protection under the PDPA.

Privacy on Our Websites

This Policy also applies to any personal data we collect via our websites. Cookies may be used on some pages of our websites. “Cookies” are small text files placed on your hard drive that assist us in providing a more customised website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If individuals are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites; however other functionality in the site may be impaired. After the visit to our site is terminated, a visitor can always delete the cookie from his system if he wishes.

Because we want visitors’ website experience to be as informative and resourceful as possible, we may provide a number of links to third-party websites. We assume no responsibility for the information practices of these third-party websites that visitors can access through ours. When visitors to our website link to these third-party websites, our privacy practices no longer apply. We encourage visitors to review each website’s privacy policy before disclosing any data.

Data Protection Officer

If an individual believes that information we hold about him is incorrect or out of date, or if an individual has concerns or further queries about how we are handling his personal data, or any problem or complaint about such matters, please contact our Data Protection Officer Nicholas Tung Kai Sheng, at [email protected]

Modifications

We reserve the right to modify or amend this Policy at any time. The effective date will be displayed at the beginning of this Policy. To keep you informed, we will notify changes to this Policy by prominently identifying the alteration for a period of not less than two weeks on our home page at http://www.freemansland.co

Recruitment Data Protection Policy

Freemansland Consultancy firm, which is established in Singapore (“FMC” or “we”) believes that privacy is an important individual right, and this policy provides information regarding our use and disclosure of personal data collected from individuals including via our websites for recruitment purposes. FMC’s information handling practices are in accordance with current privacy and data protection legislation in Singapore.

For more general information about the privacy practices of FMC, please refer to our Main Data Protection Policy.

Why do we collect personal data?

As part of our recruitment process, we collect personal data about you to consider you for employment with our firm. During the course of the recruitment and selection process, we may request further information about you to assess your suitability for positions with our firm. In doing so, we only collect personal data necessary for recruitment decisions. The procedures used by the firm to gather further information about you might include:

• selection interviews;
• written skills tests; and,
• necessary pre-employment activities.

References from your current or former employer(s) or other sources will only be obtained with your consent. In some cases, pre-employment checking may be necessary. Any checking is necessary, and the extent and nature of the information sought is no more than is justified by the particular position being filled. Failure to provide the requested information may influence the processing and outcome of your application.

How do we use personal data?

We use the personal data for the following purposes:

• managing your application(s) for employment, evaluating you for open positions throughout the FMC network, and managing your candidate profile;

• evaluating your suitability for employment with FMC (including for example, providing your personal information to third parties to conduct background checks);

• sending you messages, and other announcements, requesting additional information, or otherwise contacting you about your candidacy;

• conducting statistical analyses and reports on FMC recruitment activities and analyses of candidate sourcing channels; and

• relating to any other purposes for which you provided the information to FMC.

We will not collect or use personal data in ways other than as described in this policy unless we have obtained your consent.

Cookies and log files

This policy also applies to any personal data we collect via our websites. Cookies may be used on some areas of our website. “Cookies” are small text files placed on your hard drive that assist us in providing a more customised website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites; however, other functionality in the site may be impaired. After the visit to our site is terminated, you can always delete the cookie from your system if you wish.

To properly manage our website and related email services, we may anonymously log information on our operating systems about the number and duration of visits to our website and identify categories of visitors by items such as domains and browser types, and track enquiry ID numbers by way of email acknowledgement or return receipt. These statistics are reported in the aggregate to our system administrators. In addition, site statistics are compiled by third parties, so your IP address will be passed to third parties for statistical reporting only. This is to ensure that our website presents the best web experience for visitors and is an effective information resource.

Whenever registered member visits our website, they may be required to identify themselves to gain entry. FMC logs this data primarily to measure website performance and assist in resolving any website technical difficulties.

Disclosure of personal data

Your personal data will be used only by partners and staff directly involved in the recruitment process. Information will not be disclosed to third parties except when required by law when we have your consent or in cases where the third party is a contractor or vendor whom we have engaged specifically to assist with our firm’s activities. All such contractors will be bound contractually to keep all information confidential.

How is this information secured?

FMC has implemented generally accepted technology and operational security standards to protect your personal information from loss, misuse or destruction. In particular, FMC has put in place appropriate confidentiality obligations and technical and organisational security measures to prevent any unauthorised or unlawful disclosure or processing of such information and the accidental loss or destruction of or damage to such information.

How long is the information kept?

Because FMC must process your personal data to consider you for a position as part of the recruitment process, if you revoke your consent, FMC may need to terminate your application. FMC may retain certain information related to your application for a reasonable but limited period to meet applicable legal or records retention requirements. To request us to delete your personal data submitted to FMC, whether through our websites or otherwise, please send your request to [email protected]

Access to your personal data can be made by request to us unless granting access would infringe on another person’s privacy. If you wish to gain access to your personal data, please send your request to [email protected].

Correction and Concerns

If you believe that the information we hold about you is incorrect, if you have concerns about how we are handling your personal data, or if you changed your mind about our data usage, please email us at [email protected]. We will try to resolve those concerns.

Changes to the Freemansland Consultancy Recruitment Data Protection Policy

FMC reserves the right to modify or amend this policy at any time and for any reason. However, FMC commits to ensuring that the privacy rights of individuals are maintained.

To keep potential candidates informed, FMC will ensure that we notify users of changes to our Recruitment Data Protection Policy by identifying the alteration for a period of not less than two weeks on our home page and identifying the effective date at the beginning of this policy.

Contact our Privacy Office

We welcome your enquiries or comments about our Recruitment Data Protection Policy and any queries or concerns that you may have about this website.

Marketing Data Protection Policy

Freemansland Consultancy firm, which are established in Singapore (“FMC” or “we”) believes that privacy is an important individual right, and this policy provides information regarding our use and disclosure of personal data collected from individuals including via our websites for marketing purposes. FMC’s information handling practices are in accordance with current privacy and data protection legislation in Singapore.

For more general information about the privacy practices of FMC, please refer to our Main Data Protection Policy.

Why do we collect personal data and how do we use it?

FMC will use the personal data submitted to FMC for the purposes of any relevant marketing collaterals posted by the FMC, such as, but not limited to, seminars, firm events and news alerts on publications. We may also send you communications from time to time, for example, to advise you of technical updates or ask you to participate in surveys which may be of interest to you. By submitting the information on this website, you acknowledge that you have consented to our processing data in accordance with the privacy statement for the purposes described.

Retention of Personal Data

Personal data FMC keeps will be destroyed after 7 years from the date of the last transaction or is no longer required for the purpose for which it was collected or when we receive your request to delete it.

How is this personal data secured?

The personal data submitted to FMC is stored in our contacts database and available only to authorised FMC Marketing Officers and administrators.

Access to and Correction of Personal Data

If you wish to access, delete or correct your personal data provided to us or if you have any concerns about how we handle information about you, please send your request to our Data Protection Officer Nicholas Tung Kai Sheng, at [email protected]

Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA.

Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.

We may charge a fee of $100 for a request for access in accordance with the requirements of the PDPA.

Withdrawal of Consent

Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised under applicable laws.

Disclosure of Data to Third Parties

The personal data submitted will not be disclosed to third parties except when required by law, when we have your explicit consent or in cases where the third party is a contractor or vendor whom we have engaged specifically to assist with the Firm’s activities. All such contractors will be bound contractually to keep all information confidential.

Contact our Data Protection Officer

If an individual believes that information we hold about him is incorrect or out of date, or if an individual has concerns or further queries about how we are handling his personal data, or any problem or complaint about such matters, please contact our Data Protection Officer Nicholas Tung Kai Sheng, at [email protected]