Data Protection Notice

Welcome to ARK Connect Pte Ltd. We are an executive search and leadership transformation company. We provide a variety of services to these clients and other parties, including, but not limited to: (i) executive search; (ii) executive assessment, development and coaching; (iii) team development; (iv) organizational design; (collectively, and among others, our ''Services''). 

We respect the privacy of our clients, candidates and other users of our Services (''you'', ''your'') and are committed to protecting your personal data and information according to the applicable laws. ARK Connect Pte Ltd takes its responsibility for the processing of your personal data and information very seriously, whether provided to us on our website, via email, via social networking sites, in person or otherwise. 

This Data Protection Notice (“Notice”) sets out the basis upon which ARK Connect Pte Ltd (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of employees, freelancers, contractors, and candidates. 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.  

1-  This Notice applies to:  

• a.  persons engaged in a contract for service with us (such persons being ‘freelancers’ or ‘contractors’); 
• b.  persons engaged in a contract of service with us; 
• c.  interns working at or attached to us; 
• d.  persons who have (directly or indirectly through an agent) applied for a position with ARK Connect or our clients or have otherwise indicated an interest in working for ARK Connect in the future and have provided Personal Data during this process of engagement (“Candidate”),  

(the persons in (a), (b) and (c) above, whether on a part-time or full-time basis, and all such persons hereinafter collectively referred to as “Employee”). 

2-  In this notice, references to the term “employment” shall be construed to include employment, freelance and contract service arrangements, and internships (as may be applicable) with us.  

1-  As used in this Notice, “personal data” means data, whether true or otherwise, but as provided to us, about an Employee or a Candidate 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.

2-  If you are a candidate, personal data which we may collect includes, without limitation, your: 

• a.  name or alias and NRIC;  
• b.  mailing address, telephone numbers, email address and other contact details; c. resume, educational qualifications, professional qualifications and certifications and employment references; 
• c.  employment and training history;  
• d.  referee’s details; 
• e.  Photos and videos such as but not limited to your attendance at a video interview or training or similar sessions (you will be given a chance at the session to ask not to be videoed or photographed); 
• f.  public profile on social media (Facebook, Twitter, LinkedIn, etc.), and other public information and records, with the sole purpose of assessing and ascertaining your experience and professional skills, and to know whether your profile is consistent with the ARK Connect culture and values as part of the selection process; 
• g.  We also collect information on your visits to our website/Portal including (but not limited to) your IP address, browser, timestamp, location, country traffic data, location data, weblogs and other communication data and the resources that you access. This information will make your visit to our website/Portal easier in the future. We will, for example, suggest jobs to you which are being handled by branches local to where you were when you contacted us. 
• h.  salary information; and 
• i.  work authorization. 

3-  If you are an Employee, personal data which we may collect in the context of your employment with us includes, without limitation, your: 

• a.  name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country of birth;  
• b.  mailing address, telephone numbers, email address and other contact details; c. employment and training history;  
• c.  salary information and bank account details;  
• d.  details of your next-of-kin; 
• e.  records on leave of absence from work; 
• f.  Photographs, videos and biometric information; 
• g.  performance assessments and disciplinary records; 
• h.  any additional information provided to us by you as a job applicant (that is, prior to being engaged by us); and 
• i.  information technology related data such as logs, emails, system data and any other communication with ARK Connect systems. 

4-  Other terms used in this Notice shall have the meanings given to them in the Personal Data Protection Act (“PDPA”) (where the context so permits).  

5-  If you have provided us with any third party personal data (for example referee details, emergency contact details) you represent to us that you have obtained the third party’s consent before submitting the data to us for the relevant purposes.  

1-  Our legal basis for collecting and using your Candidate Information for the Services will depend on the Processing activity involved and the context in which it was obtained and therefore can either be based on our legitimate business interest or on your consent. 

2-  As part of Services, your Candidate Information may be Processed for the business purposes of: 

• a.  providing Services on behalf of our Clients, which may include Processing of your Candidate Information within your own integration, assessment, coaching or development as part of respective assignments for our Clients; 
• b.  operating the databases your Candidate Information is stored in; and 
• c.  analyzing your information using analytical tools and comparing the results against other Candidates or potential Candidates, including categorization of Candidates through profiles developed by the software, to assist us in conducting Services. 

3-  If you are a Candidate for Services relating to executive search, your Candidate Information may be Processed for the additional business purposes of: 

• a.  executing searches for potential Candidates on behalf of Clients that have an opening for an executive or similar management position, including, but not limited to, (i) assessing your suitability for Client opportunities, (ii) introducing you to Clients as a Candidate, (iii) verifying your educational credentials, professional diplomas and certificates, (iv) where appropriate and in accordance with applicable law, using your diversity information to provide Clients with diverse pools of qualified Candidates, and (v) ensuring that you will not be recruited on behalf of another Client unless you request consideration for other opportunities;
• b.  informing you of open executive or similar management positions potentially suitable for you; 
• c.  sending you information or materials that we believe you may find interesting, such as reports, research, invitations to networking events, or information regarding our Services, publications and surveys; and 
• d.  approaching you as a Client contact for the introduction of other Candidates or as a source of information about potential Candidates for third-party Clients. 

4-  At no point will your Candidate Information be used for purposes other than providing the Services for which your Candidate Information has been intended. 

5-  Your Candidate Information will mainly be Processed by and on behalf of ARK Consulting. However, depending on how and where the Services need to be performed in your individual case, your Candidate Information may be shared with: 

• a.  Consultants and administrative staff: Via our databases, your Candidate Information will be available to the consultants and administrative staff of ARK Connect for the purposes of providing the Services; 
• b.  Clients: If you are a Candidate for Services relating to executive search, subject to our discretion, we might disclose excerpts of your Candidate Information such as your professional education and employment history with particular Clients in order to confirm whether such Clients might be interested in you as a Candidate with respect to an opening for an executive or similar management position they have informed us of. The information disclosed will be limited to what is necessary for this purpose. We will not disclose the entirety of your Candidate Information or otherwise introduce you to any Client in detail without first obtaining a consent from you; 
• c.  Selected partners: Your Candidate Information might be Processed by selected partners with whom we may work on specific projects when providing Services, including third party agencies; 
• d.  Software service and application providers: Your Candidate Information may be Processed by the software service and application providers as our Processors (such as Microsoft Corporation or Zoom Video Communication, Inc), located anywhere in the world, subject to binding contractual obligations to only Process your Candidate Information in accordance with our prior written instructions and to apply measures to protect the confidentiality and security of your Candidate Information, together with any additional requirements under applicable law; and 
• e.  IT infrastructure service providers: Your Candidate Information will be stored on servers located in the European Union, Singapore and in the United States. The servers are operated by and accessible to designated employees of ARK Connect as well as third-party service providers acting on behalf and as per instruction of ARK Consulting, for the purposes of website management, information technology and related infrastructure provision. 
• f.  We generally collect personal data that (a) you 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 consent to the collection and usage of your personal data for those purposes, or (b) collection, use and disclosure of personal data without consent is permitted or required by the PDPA or other laws. In addition, we may collect and use any communications that originate from the connection or use of ARK Connect related services or infrastructure, which may include personal data such as device settings, emails, device logs, device information, phone number, used applications, internet use and network traffic. We endeavor to 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). 

1-  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. 

2-  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 and effect your request within thirty (30) days of receiving it.  

3-  Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, for candidates 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 11 above.

4-  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.  

1-  If you wish to make (a) a 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 (directly, or indirectly via your HR contact) at the contact details provided below. 

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. 

3-  We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within thirty (30) days after receiving your access 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 applicable law).  

4-  Please note that depending on the request that is being made, 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.  

1-  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, 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.  

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. 

3-  In the event of a notifiable data breach, which concerns your personal data you will be informed without undue delay.   

1-  We generally rely on personal data provided by you (or your authorised representative). 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 our Data Protection Officer (directly, or indirectly via your HR contact) in writing or via email at the contact details provided below.   

1-  We may retain your personal data for as long as it is necessary to fulfill the purposes for which they were collected, or as required or permitted by applicable laws. 

2-  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.    

1-  You may contact our 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 by email or post to: 

                                                                ARK Connect Pte Ltd 

                                                10 Anson Road #22-02 Singapore 079903 

                                                                      +65 60275599 

2-  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.    

EFFECT OF NOTICE AND CHANGES TO NOTICE

1-  This Notice applies in conjunction with any other policies, notices, contractual clauses, code of conduct, and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us. 

2-  We may revise this Notice from time to time by giving notice. If you are a Candidate, your continued participation in our recruitment process constitutes your acknowledgement and acceptance of such changes. As an Employee, your continued employment constitutes your acknowledgement and acceptance of such changes.