SPORTS FASHION PTE LTD’S PRIVACY AND DATA PROTECTION POLICY
Sports Fashion Pte Ltd (“SFPL”, “we”, “us” or “our”) takes its responsibilities under Singapore’s Personal Data Protection Act (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data, and we are committed to protecting your personal data. Please read this policy to understand what personal data is collected or processed by us, and what purposes it is used and/or disclosed for.
- INTRODUCTION
“Personal data” means data, whether true or not, about a living individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Personal data can be factual (such as a name, address, or date of birth) or it can be an opinion (such as a performance appraisal).
The purpose of this policy is to inform you and provide you with an understanding of how we handle, collect, use, disclose and process personal data about you that you give us, that we receive through third parties or that is in our possession.
By providing your personal data to us, you acknowledge and agree that you have fully read and understood this policy, and are consenting to the collection, use, processing, and disclosure of your personal data as described in this policy.
Without prejudice to any of the foregoing, if you provide the personal data of any other third party to us, you warrant and agree that such third party has fully read and understood this policy and has consented to you disclosing his/her personal data to us for the collection, use and disclosure by us as described in this policy.
- DEFINITION OF DATA PROTECTION TERMS
Data is recorded information whether stored electronically, on a computer, or in certain paper-based filing systems.
Data processors include any person who processes personal data on behalf of a data controller. Employees of data controllers are excluded from this definition, but it could include suppliers which handle personal data on behalf of the Company.
Personal data means any data relating to a living individual who can be identified from that data. Personal data can be factual (such as a name, address, or date of birth) or it can be an opinion (such as a performance appraisal). It can even include a simple e-mail address. It is important that the information has the data subject as its focus and affects the individual’s privacy in some way.
Processing is any activity that involves use of the data. It includes obtaining, recording, or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing, or destroying it. Processing also includes transferring personal data to third parties.
Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
- COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
Personal data which we may collect includes, without limitation, your:
(a). First and last name alias, NRIC/FIN or passport number, date of birth, nationality, and country and city of birth
(b). Mailing address, telephone numbers, email address and other contact details
(c). Resume, educational qualifications, professional qualifications, certifications, and employment references.
(d). Employment and training history
(e). Work-related health issues and disabilities and
(f) . Photographs.
Your personal data which we collect will be used by us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:
(a). assessing and evaluating your suitability for employment in any current or prospective position within the organization and
(b). verifying your identity and the accuracy of your personal details and other information provided. We shall seek your consent before using your personal data for a purpose that has not been notified to you (except where permitted or authorized by law)
- 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 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.
In general, we shall seek to process and effect your written request to withdraw your consent within [30] days of receiving it.
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. 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.
Please note that 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.
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 below.
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.
We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within [30] days after receiving your access request, we will inform you in writing within [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 the PDPA).
6. ACCURACY OF PERSONAL DATA
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 in writing or via email at the contact details provided below.
7. RETENTION OF PERSONAL DATA
Security of your personal data is important to us. We take appropriate action to protect personal data from loss, misuse, unauthorised access or disclosure, alteration or destruction using the same safeguards as we use for our own proprietary information.
We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that:
(a) We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.
(b) 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.
- DATA PROTECTION OFFICER
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 following manner:
Name: Baidya Augustin
Email: admin@sfpl.com.sg
9. EFFECT OF POLICY AND CHANGES TO POLICY
This Policy 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 Policy from time to time without any prior notice.
Effective date: [21st August 2023]
Last updated: [23rd August 2023]